Private ruling: Do the activities of the taxpayer amount to permanent establishment in Australia
Published: June 2013
Ruling period: Year ending 31 December 2013.
Date scheme commenced: 1 January 2013.

Ruling: Q1: Do the activities of the taxpayer amount to a permanent establishment in Australia under Article 5 of the Convention between the Government of Australia and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains [2003] ATS 22 (UK Convention)? | A1: Yes.



Reasons for decision: Summary: The private binding ruling concerned whether or not the activities of the taxpayer amount to a permanent establishment in Australia under Article 5 of the UK Convention. The Commissioner of Taxation ruled that the activities of the taxpayer amount to a permanent establishment in Australia under Article 5 of the UK Convention.