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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Australia: Residence

The Agreement contains definitions of resident that are broadly in line with standard OECD definitions (see INTM159034). The Agreement applies from 1st April 2004 for UK corporation tax, 6th April 2004 and 1st July 2004 for Australian tax.

There is an exception for companies participating in a dual listed company arrangement. For these see DT2654A.