DT2717 - DT: Australia: old agreement, Article 18: Dual residents

This agreement applies up to 5th April 2004 for UK income and capital gains tax, up to 31st March 2004 for UK Corporation tax and up to 30th June 2004 for Australian taxes and UK withholding taxes. There is no equivalent for later periods.

(18)(1) This Article shall apply to a person who is a resident of Australia and is also resident in the United Kingdom.

(2) Where such a person is treated for the purposes of this Agreement solely as a resident of one of the territories he shall be exempt in the other territory from tax on any income in respect of which he is subject to tax in the first-mentioned territory if the income is derived -

(a) from sources in the first-mentioned territory; or
(b) from sources outside both territories.