Australia Clarifies Straddle Holding Period Rule for Dividend Withholding Tax under Tax Treaties

The Australian Taxation Office (ATO) has published guidance on the application of the straddle holding period rule for dividend withholding tax under Australia's tax treaties.

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Straddle holding period rule

Under particular tax treaties, including some of those modified by Article 8 of the Multilateral Instrument, non-portfolio intercorporate dividends may become eligible for reduced withholding tax rates if the beneficial owner of the dividend satisfies the straddle holding period ru…