2. The competent authority terminates its decision where it considers that the request is justified and that it is itself unable to find an appropriate solution to resolve the case with the competent authority of the other State party, in order to avoid taxation that is not in accordance with this agreement. The solution thus found will be transposed into the national legislation of the contracting states, regardless of the possible time frame. The Multilateral Agreement on the Implementation of Tax Convention Measures to Prevent Base Erosion and Profit Shifting, also known as the Multilateral Instrument (IIM), is a multilateral treaty that allows legal systems to rapidly amend their tax treaties to implement measures to better combat multinational tax evasion and resolve tax disputes more effectively. (3) The agreement signed in Canberra on 31 May 1983 between the Government of Australia and the Government of the Republic of India to avoid the double taxation of international air transport revenues, signed in Canberra on 31 May 1983 (in this article entitled “The 1983 Convention”), no longer takes effect with respect to the taxes to which this agreement applies when the provisions of this agreement , as referred to in paragraph 1, come into force. Tax treaties are formal bilateral agreements between two jurisdictions. Australia has tax agreements with more than 40 jurisdictions. 2. This article does not affect the application of a contracting state`s right to determine a person`s tax debt, including findings where information available to the state`s tax administration is not sufficient to determine income attributable to a business, to the extent that that law is applicable. , to the extent possible, contrary to the principles set out in this article. 1.
Where a person established in one of the contracting states believes that the actions of the tax authority of one or both contracting states result in or will stand for the person who does not comply with the provisions of this agreement, the person may, notwithstanding the remedies provided by the national legislation of those states, the competent authority of the contracting state whose person is domiciled. , to complain. The case must be brought within three years of the first notification of the tax action, which is not in accordance with this agreement. 6. Nothing in this agreement affects the application. A State party`s right to the taxation of capital gains resulting from the disposal of assets other than that to which one of paragraphs 1, 2, 3, 4 and 5 applies. Most tax treaties include a “Tiebreaker” exam in which a dual resident is considered only a resident of one of the two tax regulations. 1. The competent authorities of the contracting states exchange the information necessary for the application of this agreement or the national legislation of the contracting states with respect to the taxes to which this agreement applies, as long as the imposition of this agreement is not contrary to this agreement, or in order to prevent tax evasion or evasion or fraud relating to , such as taxes.