Private ruling: Exemption of Australian interest withholding tax
Published: November 2012
Ruling period: 3 years
Date scheme commenced: 2012

Ruling: Q1: Is the foreign government entity entitled to an exemption from liability to interest withholding under Article 11(3) of the International treaty between the foreign country and Australia in respect of interest derived from debt instruments entered into by Australian borrowers? | A1: Yes.

Relevant facts and circumstances: The foreign government entity lends to Australians who import the foreign country goods. The entity uses the funds of the official reserve assets of the foreign government.

Relevant legislative provisions: Treaty between the foreign country and Australia

Reasons for decision: Summary: The treaty provides that interest derived from Australian loans is exempt from Australian withholding tax provided the investment is made from official reserve assets

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