ATO Issues Guidance on How to Evidence Double Tax Agreement Residency in Arrangements Involving Fiscally Transparent Entities

The Australian Taxation Office (ATO) has issued new guidance on how to evidence double tax agreement residency in arrangements involving fiscally transparent entities.

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Fiscally transparent entities and tax treaty residency claims

How to evidence double tax agreement (DTA) residency in arrangements involving fiscally transparent entities (FTEs).

What are fiscally transparent entities

An entity is a fiscally transparent entity (FTE) where, under the domestic law of a contracting state, …