Private ruling: International treaty and sovereign immunity
Published: July 2013
Ruling period: 1 July 2013 to 30 June 2018
Date scheme commenced: 1 July 2008

Ruling: Q1: Is the foreign government entity exempt from dividend and interest withholding taxes on Australian income under its country's treaty with Australia? | A1: Yes | Q2: Is the foreign government entity exempt from sundry other income on its Australian income under the common law principles of sovereign immunity | A2: Yes

Relevant facts and circumstances: The foreign government entity invests funds derived from fees raised for an accident compensation scheme.

Relevant legislative provisions: International Agreement

Reasons for decision: Summary: The foreign government entity satisfies the conditions of the international treaty for exemption from dividend and interest withholding taxes on its Australian investments and under the doctrine of sovereign immunity for its other income derived from MITs and VCLPs.