No Equivalent Sample Clauses

No Equivalent. There is no equivalent to Art 13 in the UK, Japan and Germany DTAs.20 Each of these agreements were negotiated and entered into prior to the introduction of CGT in Australia. Profits made by a UK resident, for example, from the disposal of shares in an Australian entity are likely to be subject to CGT. Any relief from double taxation must be obtained from the other articles of each DTA.21

No Equivalent. The bilateral tax agreements between Australia and the United Kingdom, Japan, Germany, the Netherlands, France, Belgium, the Philippines, Switzerland, Malaysia and Italy do not contain an equivalent to Art 21 of the OECD Convention. XxXxxx J in Xxxxx thought it "significant" that the Swiss agreement did not contain an equivalent to Art 21,64 for reasons which he did not elaborate. In any event, he held that the Swiss taxpayer was still entitled to relief from Australian tax. Consequently, a resident of these foreign jurisdictions which disposes of Australian shares must rely on other articles of the DTAs for relief from double taxation.