Document ID: chunk:federal_register_of_legislation:C2004A01208:schedule:47:p1
Version: federal_register_of_legislation:C2004A01208
Segment Type: schedule
Provision Reference: sch 47 (pt 1/25)
Character Range: 90018–92911

Schedule 47—Mexican agreement and protocol

Note: See section 3.

AGREEMENT BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE UNITED MEXICAN STATES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

 The Government of Australia and the Government of the United Mexican States, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, which shall hereafter be referred to as the "Agreement",

 Have agreed as follows:

Article 1

PERSONS COVERED

 This Agreement shall apply to persons who are residents of one or both of the Contracting States.

Article 2

TAXES COVERED

1 The existing taxes to which this Agreement shall apply are:

 (a) in Mexico:

 the federal income tax (el impuesto sobre la renta federal);

 (b) in Australia:

        the income tax, and the resource rent tax in respect of offshore projects relating to exploration for or exploitation of petroleum resources, imposed under the federal law of Australia.

2 This Agreement shall apply also to any identical or substantially similar taxes which are imposed under the federal laws of Mexico and Australia after the date of signature of this Agreement in addition to, or in place of, the existing taxes.  The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in the laws of their respective States relating to the taxes to which this Agreement applies, and to its application, within a reasonable period of time after those changes.

Article 3

GENERAL DEFINITIONS

1 For the purposes of this Agreement, unless the context otherwise requires:

        (a) the term "Mexico" means the United Mexican States; when used in a geographical sense, it includes the territory of the United Mexican States: being the integrated parts of the Federation; the islands, including the reefs and cays in the adjacent waters; the islands of Guadalupe and Revillagigedo; the continental shelf and the seabed and submarine shelves of the islands, cays and reefs, where Mexico may exercise sovereign rights in accordance with international law; the waters of the territorial seas to the extent and limits established by international law and the inland waters; and the airspace of the national territory to the extent and upon the conditions established by international law; and the exclusive economic zone outside the territorial sea within which Mexico may exercise sovereign rights in accordance with its domestic law and international law;

        (b) the term "Australia", when used in a geographical sense, excludes all external territories other than:

 (i) the Territory of Norfolk Island;

 (ii) the Territory of Christmas Island;

 (iii) the Territory of Cocos (Keeling) Islands;

 (iv) the Territory