Although not much has happened on the surface since the US protocol and UK treaty were signed, Australia has actively been renegotiating treaties. In addition the ATO and the OECD produce a stream of treaty related material and the legislature tweaks domestic law to fit with treaties better (eg for employee share options). Issues covered in this paper include:
- what have been the flow on impacts of the US / UK Treaty protocols?
- what are the current trends for upcoming treaty negotiations?
- recent OECD developments and recent Australian rulings and treaty related legislation.