Constructors uses a different firm of consulting engineers for this project. During the period of its operations in Australia, an employee identified land near one of the sites which he considered could be purchased and sold at a considerable profit. The land was quickly onsold at a substantial profit effected by a sale of the shares in Constructors subsidiary. Manufactures Ltd which is resident in Europa has a branch in Australia. Manufacturers also wishes to know whether it is possible to be taxed on a profit in Australia when overall it makes a loss if the results in Europa and Australia in relation to products sold in Australia are combined.
Geologist is a resident of Europa.
Her business is to conduct geological surveys to gain information to be used by clients in prospecting for minerals. Under a contract with Oil Ltd., she has carried out a survey of potential oil bearing structures in Australia. Assume that oil has been discovered and is being produced. Consider the Australian tax treaty implications for Geologist. Albert is working as a mining engineer for Conglomerate Inc in Utopia.