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Tax treaty with Australia updated for MLI

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HMRC has published the ‘synthesised’ text of the UK’s double taxation convention with Australia, as modified by the BEPS multilateral instrument (MLI). The MLI came into force for the UK on 1 October 2018 and for Australia on 1 January 2019.

The modified convention is effective from:

  • 1 January 2019 for taxes withheld at source on amounts paid or credited to non-residents;
  • 1 April 2020 in the UK for corporation tax;
  • 6 April 2020 in the UK for income tax and CGT; and
  • 1 July 2019 in Australia for all other taxes for taxable periods beginning on or after that date.

The authentic legal texts of the 2003 double tax convention and the MLI take precedence and remain the legal texts applicable. See

The MLI allows jurisdictions to integrate elements of the OECD/G20 BEPS project into their existing bilateral tax treaties. HMRC published the final list of UK reservations and notifications for the UK’s ‘covered tax agreements’ under the MLI in July 2018.

Issue: 1436
Categories: News