The Australian Taxation Office issued on 2 May 2008 Interpretative Decision ATO ID 2008/63 in which it said that an Irish Common Contractual Fund (CCF) is not a resident for the purposes of the tax treaty between Australia and Ireland. In reaching this conclusion, the Interpretative Decision states that the residence of trustees of a CCF is determinative in deciding the residence of the CCF. The trustees do not satisfy the residence requirements, as they are not liable to tax in Ireland on income they receive in their capacity of trustees of CCF, and the CCF itself is treated as...