Document ID: chunk:federal_register_of_legislation:C2004A02224:body:0:p8
Version: federal_register_of_legislation:C2004A02224
Segment Type: other
Provision Reference: 
Character Range: 16944–19774

of the other territory any tax in the nature of an undistributed profits tax on undistributed profits of the company on a basis that is less favourable than that applicable in the case of a company which is a resident of the first-mentioned territory."
ARTICLE III
This Protocol, which shall form an integral part of the Agreement, shall enter into force on the date when the last of all such things shall have been done in the United Kingdom and Australia as are necessary to give the Protocol the force of law in the United Kingdom and Australia respectively, and shall thereupon have effect:
     (a) in the United Kingdom:
          (i) as regards Article I, for any year of assessment beginning on or after 6 April 1980;
          (ii) in relation to any dividend paid on or after 6 April 1977;
     (b) in Australia:
          (i) as regards Article I, for any year of income beginning on or after 1 July 1980;
          (ii) in relation to any dividend paid on or after 6 April 1977.
In witness whereof the undersigned, duly authorized thereto by their respective Governments, have signed this Protocol.
Done in duplicate at Canberra this twenty-ninth day of January, One thousand nine hundred and eighty.
JOHN HOWARD                                           DONALD TEBBIT
For the Government of the Commonwealth of Australia:  For the Government of the United Kingdom of Great Britain and Northern Ireland:

                     SCHEDULE 2 Sections 8
SCHEDULES TO BE ADDED AT THE END OF THE PRINCIPAL ACT
—————
                     SCHEDULE 14 Sections 3
AGREEMENT
BETWEEN
THE GOVERNMENT OF AUSTRALIA
AND
THE GOVERNMENT OF THE REPUBLIC OF THE PHILIPPINES
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 Republic of the Philippines,
Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income,
Have agreed as follows:
Chapter 1
SCOPE OF THE AGREEMENT
ARTICLE 1
Personal Scope
(1) This Agreement shall apply to persons who are residents of one or both of the Contracting States.
(2) However, nothing in this Agreement shall prevent the Philippines from taxing its own citizens, who are not residents of the Philippines, in accordance with Philippine law.
ARTICLE 2
Taxes Covered
(1) The existing taxes to which this Agreement shall apply are—
     (a) in Australia:
     the Australian income tax, including the additional tax upon the undistributed amount of the distributable income of a private company;
     (b) in the Philippines:
     the income taxes imposed by the Government of the Republic of the Philippines.
(2) This Agreement shall also apply to any identical or substantially similar taxes which are imposed by either