The Australian Taxation Office (ATO) released for discussion Draft Taxation Ruling TR 2006/D8 dealing with the tax treatment of shipping and aircraft leasing profits of UK and US enterprises under the corresponding tax treaties with the United Kingdom and the United States.. The Draft Ruling discusses situations when leases of ship and aircraft may result in the enterprises having a substantial equipment permanent establishment (PE) in Australia. The Draft Ruling does not cover leases entered into with a purpose of purchasing the equipment. Further, the Draft Ruling does not apply to profits covered by Art. 8 of the respective tax...