ATO releases Taxpayer Alert on treaty shopping arrangements – 21 July 2022

On 20 July 2022, the Australian Taxation Office published Taxpayer Alert TA 2022/2 on “treaty shopping arrangements designed to obtain” reduced withholding tax rates. The Commissioner has issued this Taxpayer Alert to inform taxpayers that the ATO is currently reviewing certain perceived treaty shopping arrangements in relation to royalty or dividend payments from Australia paid to an “interposed entity” that is a resident of a treaty partner jurisdiction.

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