Double Tax Agreement Australia And Switzerland
2.8 An amendment is made to clarify that any reference in an international agreement to the concept of «immovable property», with its meaning in Australian national law, also includes a reference to immovable property. [Schedule 1, Item 8, Agreements Act 1953 Subsection 3 (5)] 2.10 None of Australia`s current international agreements uses the term «fixed assets». 1.124 If profits are redistributed and the profits of an enterprise in one country are increased, this would result in economic double taxation (i.e., the taxation of the same income in the hands of different persons) if the profits thus redistributed continued to be taxed in the hands of a related enterprise in the other country. To avoid this result, the other country is required to make an appropriate compensatory adjustment to the amount of tax levied on the profits concerned in order to reduce such double taxation. The Federal Council`s decision is implemented in bilateral double taxation agreements. The greater scope for the exchange of information will only have practical effect when the renegotiated agreements enter into force. It is also necessary to adapt the agreement with the EU on the taxation of savings. (7) For the purposes of paragraph 3 of Article XXII (Consultation) of the General Convention on Trade in Services, the Contracting States agree that, notwithstanding this paragraph, any dispute between them as to whether a measure falls within the scope of this Convention may be submitted to the Council for Trade in Services in accordance with this paragraph, only with the agreement of the two Contracting States. .