Tax Agreement Australia Canada

5.74 It is important that the tax-saving measures in the second proposed protocol were deemed necessary during the negotiations in order to obtain approval for other measures of the second protocol. This includes updating the existing DBA to reflect Australia`s current contractual practices in a number of areas, including the application of the Labuan preferential regime. 5.31 The negotiation of an amendment protocol (involving a formal round of negotiations in Australia) and the subsequent adoption of the resulting amendments resulted in a cost of approximately $46,000. Most of these costs were borne by the ATO, although other agencies, such as the Department of Finance and the Department of Foreign Affairs and Trade, would bear some of these costs. It would also be uns quantified costs in terms of parliamentary time and the development of funds for the implementation of the 1980 DTC amendments, although this would not be important, based on similar agreements in the past. 5.13 In August 2001, Canada concluded 71 bilateral tax agreements (including about 8 others, but not yet in force) and is negotiating with some 22 countries. In general, Canada sticks to the OECD model. 5.32 There is already a small uns quantified “maintenance cost” for the ATO in the 1980 DTC management for application processing, mutual agreement procedures and pre-price agreements, OECD representation, etc. Any change to the 1980 DTC would result in new minor implementation costs for the ATO.

1.67 Section 24, paragraph 6, of the agreement is introduced to require the agreement of Australia and Canada before a dispute over whether a measure falls within the scope of the tax treaty that can be submitted to the Services Trade Council. [New paragraph (6)] 6. For the purposes of Article XXII, paragraph 3 (consultation) of the General Convention on Trade in Services, States Parties agree that, notwithstanding this paragraph, any dispute between them as to whether a measure falls within the scope of this Convention can only be submitted to the Council for Trade in Services in this paragraph with the agreement of both States Parties. Any doubts about the interpretation of this paragraph are removed in accordance with paragraph 3 of this article or, in the absence of agreement on this procedure, according to another procedure agreed by the two States Parties.