DT2654 - Particular agreements: Australia: Residence

The new Agreement contains definitions of resident that are broadly in line with standard OECD definitions (see INTM159034). The new Agreement applies from 1st April 2004 for UK corporation tax, 6th April 2004 and 1st July 2004 for Australian tax.

There is an exception for companies participating in a dual listed company arrangement. For these see DT2654A.

The definitions of a resident in the old agreement of one or other of the two countries, especially as regards companies, differ from the definitions in most other agreements and careful attention should be paid to them if a case arises (see Article 3).