Document ID: chunk:federal_register_of_legislation:C2007A00136:schedule:11:p28
Version: federal_register_of_legislation:C2007A00136
Segment Type: schedule
Provision Reference: sch 11 (pt 28/28)
Character Range: 71099–72688

the Convention.

2. With reference to paragraph 5 of Article 4 (Residence),

where a resident of a third State is a member of such partnership or group that is not subject to corporation tax in France, the Australian income tax liability in respect of the member's share of the income, profits or gains of the partnership or group shall be determined in accordance with Australian domestic law, including the provisions of any taxation convention between Australia and that third State, it being understood that such partnership or group shall be treated as fiscally transparent for the purposes of entitlement to Australian tax benefits under that convention.

3. With reference to Article 12 (Royalties),

the term "royalties" does not include payments for the use of spectrum licenses.  The provisions of Article 7 of the Convention shall apply to such payments.

4. With reference to Article 18 (Government service),

business activities carried on by a statutory body of a Contracting State include activities of that body which are not primarily supported by public funds of that State or of one or more political subdivisions or local authorities thereof.

In witness whereof the undersigned, duly authorised thereto, have signed this Convention.

Done in duplicate at Paris this twentieth day of  June two thousand and six in the English and French languages, both texts being equally authentic.

FOR THE GOVERNMENT OF  FOR THE GOVERNMENT OF
AUSTRALIA:             THE FRENCH REPUBLIC:

ALEXANDER DOWNER       PHILIPPE DOUSTE‑BLAZY

[Signatures omitted]