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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Australia: Residence: Dual listed companies

The most recent Agreement applies from 6th April 2004 for UK income tax and 1st April 2004 for corporation tax and from 1st July for Australian taxes.

It contains a special provision relating to dual listed companies. Under Article 4(5), a company which is a participant in a dual listed company arrangement shall be deemed to be a resident only of the territory in which it is incorporated, provided its primary stock exchange listing is also in that State.

There is a definition of dual listed company arrangement. As at January 2004, there were only a handful of these in existence.

This effectively preserves the position these had under the previous Agreement.