Tax Agreement Between Ireland And Australia

(a) an agreement that, under this Act, has the force of law; or (a) an agreement resolves provisions concerning income, profits or profits resulting from the sale or disposal of shares or similar shares in undertakings or other entities whose assets consist wholly or mainly of immovable property (within the meaning of the agreement) or other shares relating to land; and footnote 2: Paragraph 11R gives force of res judicata to this agreement. 3AAA. Definitions – current agreements…… 5 (a) is derived from a person residing in the Federal Republic of Germany within the meaning of the 1972 German Convention; and, in both cases, in their commercial or financial relations, conditions different from those which may be expected to operate between independent undertakings which act completely independently of each other then apply to all the profits which might have been expected, under those conditions, to go to one of the undertakings, but that they were not generated in this way, in the profits of this company and be taxed accordingly. (b) the licensee or authorised person is established in a country (other than Australia) or territory (other than a territory controlled by Australia) to which an agreement applies; and 3. Where, in accordance with the provisions of paragraph 1 or 2, profits in which an enterprise in one territory has been taxed in that territory are also included in the profits of an enterprise in the other territory and subject to tax in that other area, the profits so included shall be profits which might have been expected to be paid to that enterprise in the other territory: where the conditions between them were undertakings which might have been expected to operate between independent undertakings which act independently of each other, the first zone shall make an appropriate adjustment to the amount of tax levied on those profits in the first area. The other provisions of this Agreement shall be duly taken into account when making such an adaptation and, to that end, the competent authorities shall consult each other, where appropriate. 11ZCA. Exchange of notes between Australia and Vietnam…………..

40 (b) as regards taxes other than withholding tax – in respect of income in the year of income beginning on 1 July 1969 or in a subsequent year of income for which the agreement remains effective. . . . .