The treaties with Europe have various advantages. Among those with Asian countries, the provisions for interest in the Singapore treaty and those for dividends in the Indonesia treaty deserve special mention. The treaties with countries in Southern Africa are specially attractive. The purpose of a treaty is to encourage international trade. Each Article in the OECD model has an extensive commentary.
Provision is made for transfer pricing and exchange of information.
And most treaties are between high-tax countries. They do not cover indirect taxes. It does not extend to a buying office or to a general agent acting in the ordinary course of his business. In the absence of a permanent establishment, business profits are generally taxed only in the country of residence. In the Lamesa case, the Australian court held that the capital gains tax did not apply though a company with several layers of subsidiaries, the last of which held real property in Australia.