If the election referred to in paragraph 6 were exercised, the person in Canada would be presumed to have transferred the interest under Australian tax law just before the end of his domicile in Australia. The provisions of the Convention would then ensure that an adequate exemption from double taxation is granted. Relief may not be necessary because Canada is unlikely to tax a person who is not resident in Canada on the disposal of a foreign asset. Canada would be able to tax the change capital gain after residency on the subsequent disposal of the interest. Tax exemption was a traditional feature of Australia`s double taxation treaties, but in May 1997 the government announced the abandonment of Australia`s long-standing commitment to tax relief. (5) The final expiring provisions on fiscal evasion are contained in the Double Taxation Convention with Vietnam and expire on 30 June 2003. (6) 5.41 In particular, a revision of the 1980 CTD is expected to result in a reduction in Canadian taxation of dividends and interest, which would directly benefit Australian investors in Canada. The costs associated with Australian investments in Canada`s operations and the international competitiveness of those who wish to lend to Canadian companies would be increased by these lower interest rates and the freedom to structure these activities would be greater, which should even reduce the costs of these companies. The explanatory memorandum to the bill states that one of the government`s main objectives in the negotiations that led to the second protocol was the exclusion of the Malaysian Labuan tax from the treaty. (8) The explanatory memorandum also states that the continuation of the tax-saving measures was an essential element of the negotiations with a view to obtaining the agreement of the Government of Malaysia on the exclusion of the labuan preferential tax regime. (9) Below you will find the list of countries with which Malaysia has a double taxation agreement (DTT): 5.26 The main groups initially affected by a reduction in the dividend tax rate in Canada and by an overall coverage of capital gains taxation in the DTC are probably the 38 large Australian companies investing in Canada and the Canadian companies listed in Australia. People affected by changes in investment flows between countries would also be affected.

All Australian banks that lend to Canadian residents should also benefit from reduced Canadian withholding taxes. The small number of mining companies operating between the two countries may be affected by changes to the “essential equipment” provisions. – the distribution of profits between related parties and persons on the basis of commercial comparisons and foreign companies; 2.21 The new article assigns to both countries tax duties on income that has not been covered by the previous articles of the agreement. .