DT2710 - DT: Australia: old agreement, Article 11 Independent personal services

This agreement applies up to 5th April 2004 for UK income and capital gains tax and up to 30th June 2004 for Australian taxes and UK withholding taxes. For later periods income from independent personal services is dealt with as Business Profits. See See Article 7 of the Agreement which be can be accessed via the page Tax Treaties – in force http://www.hmrc.gov.uk/international/in_force.htm.

Income derived by a resident of one of the territories in respect of professional services or other independent activities of a similar character shall be subjected to tax only in that territory unless he has a fixed base regularly available to him in the other territory for the purpose of performing his activities. If he has such a fixed base, such part of that income as is attributable to that base shall be deemed to have a source in, and may be taxed in, that other territory.