Selected aspects of Australia's emerging "model" double taxation treaty

This article examines selected aspects of Australia's emerging "model" tax treaty which reflects the changes in its tax treaty policy. The article first summarizes the findings and recommendations of the Review of Business Taxation and the Review of International Taxation Agreements in respect of Australia's treaty policy. The article then discusses the changes in Australia's tax treaty policy, which include (a) moving towards a more residence-based treaty policy, (b) giving priority to (re)negotiating treaties with Australia's major trading partners, (c) modernizing Australia's treaty policy - pertaining to e.g. exchange of information, assistance in collection and non-discrimination, and (d) improving the consultation processes on negotiating treaties. The article concludes that, going forward, Australia's "model" treaty will more closely resemble the OECD Model as, in economic terms, Australia moves from being a capital importer to being a capital exporter.