ATO Issues Taxpayer Alert on Treaty Shopping Arrangements

The Australian Taxation Office (ATO) has announced the issuance of Taxpayer Alert (TA) 2022/2 on treaty shopping arrangements.

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Taxpayer Alert issued on treaty shopping arrangements

We have released a Taxpayer Alert (Alert) outlining our concerns about treaty shopping arrangements designed to obtain the benefit of a reduced withholding tax rate under a double tax agreement (DTA) in relation to royalty or dividend payments from Australia.

The Alert highlights:

• that we are likely to m…