The allocation of taxing rights of ship and aircraft leasing profits under Australia's tax treaties
Sadiq, Kerrie (2008) The allocation of taxing rights of ship and aircraft leasing profits under Australia's tax treaties. Australia and New Zealand Maritime Law Journal, 22(1), pp. 220-227.
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The Australian Federal Commissioner of Taxation recently released Draft Taxation Ruling TR 2008/D3 with the stated purpose of clarifying ‘what profits derived from the leasing of ships or aircraft fall within the ship and aircraft articles of each of Australia’s tax treaties’. In particular, TR 2008/D3 explains the taxing rights over different types of leasing profits, such as a full basis lease in respect of any transport by a ship operated in international traffic and bareboat leases which are ancillary to the lessor transport operations of ships in international traffic. This article outlines the Commissioner’s views on the application of the standard ships and aircraft articles in the tax treaties to which it is a party as well as considering the major variations on the standard adoption. In doing so, guidance is provided as to the allocation of taxing rights of ship and aircraft leasing profits under Australia’s tax treaties.
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|Item Type:||Journal Article|
|Keywords:||Draft Taxation Ruling, TR 2008/D3, leasing profits|
|Subjects:||Australian and New Zealand Standard Research Classification > COMMERCE MANAGEMENT TOURISM AND SERVICES (150000) > ACCOUNTING AUDITING AND ACCOUNTABILITY (150100) > Accounting Auditing and Accountability not elsewhere classified (150199)|
|Divisions:||Current > QUT Faculties and Divisions > QUT Business School|
Current > Schools > School of Accountancy
|Deposited On:||19 Apr 2012 08:18|
|Last Modified:||26 Jun 2012 08:59|
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