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Trusts and Double Taxation Agreements


  • John Prebble


Professor Prebble’s paper considers the correct interpretation of double tax agreements in the context of locally resident accumulation trusts established in New Zealand or Australia, that have foreign settlors and foreign-source income. He explores the relevance and application of double tax agreements intended to minimise double taxation between New Zealand or Australia on the one hand and the source country on the other hand. In the process he identifies a difference in approach in Australia compared to New Zealand as they accord different treatment to accumulation trusts that have foreign settlors and foreign source income. The paper explores the reasons for, and the implications of, the different outcomes highlighting some key issues in tax administration where international tax is concerned.

Suggested Citation

  • John Prebble, 2005. "Trusts and Double Taxation Agreements," Taxation eJournal of Tax Research , ATAX, University of New South Wales.
  • Handle: RePEc:nsw:discus:223

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    double tax agreements; trusts; New Zealand; Australia; foreign-source income; international tax; tax administration;

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