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This is a Bill, not an Act. For current law, see the Acts databases.

INTERNATIONAL TAX AGREEMENTS AMENDMENT BILL (NO. 1) 2009

2008-2009
The Parliament of the
Commonwealth of Australia
HOUSE OF REPRESENTATIVES
Presented and read a first time
International Tax Agreements
Amendment Bill (No. 1) 2009
No. , 2009
(Treasury)
A Bill for an Act to amend the International Tax
Agreements Act 1953, and for related purposes
i International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
Contents
1
Short title ............................................................................................ 1
2
Commencement .................................................................................. 1
3
Schedule(s) ......................................................................................... 1
Schedule 1--International Tax Agreements Act 1953
3
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 1
A Bill for an Act to amend the International Tax
1
Agreements Act 1953, and for related purposes
2
The Parliament of Australia enacts:
3
1 Short title
4
This Act may be cited as the International Tax Agreements
5
Amendment Act (No. 1) 2009.
6
2 Commence ment
7
This Act commences on the day on which it receives the Royal
8
Assent.
9
3 Schedule(s)
10
Each Act that is specified in a Schedule to this Act is amended or
11
repealed as set out in the applicable items in the Schedule
12
2 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
concerned, and any other item in a Schedule to this Act has effect
1
according to its terms.
2
3
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 3
1
Schedule 1
--
International Tax Agreements Act
2
1953
3
4
1 Subsection 3(1)
5
Insert:
6
the British Virgin Islands agreement means the Agreement
7
between the Government of Australia and the Government of the
8
British Virgin Islands for the allocation of taxing rights with
9
respect to certain income of individuals, being the agreement a
10
copy of which is set out in Schedule 48.
11
2 Subsection 3(1)
12
Insert:
13
the Isle of Man agreement means the Agreement between the
14
Government of Australia and the Government of the Isle of Man
15
for the allocation of taxing rights with respect to certain income of
16
individuals and to establish a mutual agreement procedure in
17
respect of transfer pricing adjustments, being the agreement a copy
18
of which is set out in Schedule 49.
19
3 After section 11ZL
20
Insert:
21
11ZM Agreement with the British Virgin Islands
22
Subject to this Act, on and after the date of entry into force of a
23
provision of the British Virgin Islands agreement, the provision has
24
the force of law according to its tenor.
25
11ZN Agreement with the Isle of Man
26
Subject to this Act, on and after the date of entry into force of a
27
provision of the Isle of Man agreement, the provision has the force
28
of law according to its tenor.
29
4 At the end of the Act
30
Add:
31
Schedule 1 International Tax Agreements Act 1953
4 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
Schedule 48--The British Virgin Islands
1
agreement
2
Note:
See section 3.
3
4
AGREEMENT BETWEEN THE GOVERNMENT OF AUSTRALIA AND
5
THE GOVERNMENT OF THE BRITISH VIRGIN ISLANDS FOR THE
6
ALLOCATION OF TAXING RIGHTS WITH RESPECT TO CERTAIN
7
INCOME OF INDIVIDUALS
8
The Government of Australia and the Government of the British Virgin
9
Islands ("the Contracting Parties"):
10
Recognising that the two Governments have concluded an Agreement for the
11
Exchange of Information Relating to Taxes; and
12
Desiring to conclude an Agreement for the allocation of taxing rights with
13
respect to certain income of individuals;
14
Have agreed as follows:
15
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 5
ARTICLE 1
1
PERSONS COVERED
2
This Agreement shall apply to persons who are residents of one or both
3
of the Contracting Parties.
4
ARTICLE 2
5
TAXES COVERED
6
1
The existing taxes to which this Agreement shall apply are:
7
(a)
in Australia, the income tax imposed under the federal law of
8
Australia
9
(hereinafter referred to as "Australian tax").
10
(b)
in the British Virgin Islands, such taxes on income or profits as
11
imposed by law (hereinafter referred to as "British Virgin Islands
12
tax").
13
Schedule 1 International Tax Agreements Act 1953
6 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
2
This Agreement shall also apply to any identical or substantially similar
1
taxes which are imposed after the date of signature of this Agreement in
2
addition to, or in place of, the existing taxes. The competent authorities of the
3
Contracting Parties shall notify each other within a reasonable period of time of
4
any substantial changes to the taxation laws covered by this Agreement.
5
3
This Agreement shall not apply to taxes imposed by states,
6
municipalities, local authorities or other political subdivisions, or possessions of
7
a Contracting Party.
8
ARTICLE 3
9
DEFINITIONS
10
1
For the purposes of this Agreement, unless the context otherwise
11
requires:
12
(a)
the term "Australia", when used in a geographical sense, excludes
13
all external territories other than:
14
(i)
the Territory of Norfolk Island;
15
(ii) the Territory of Christmas Island;
16
(iii) the Territory of Cocos (Keeling) Islands;
17
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 7
(iv) the Territory of Ashmore and Cartier Islands;
1
(v) the Territory of Heard Island and McDonald Islands; and
2
(vi) the Coral Sea Islands Territory,
3
and includes any area adjacent to the territorial limits of Australia
4
(including only the Territories specified in this subparagraph) in
5
respect of which there is for the time being in force, consistently
6
with international law, a law of Australia dealing with the
7
exploration for or exploitation of any of the natural resources of the
8
exclusive economic zone and the seabed and subsoil of the
9
continental shelf;
10
(b)
the term "British Virgin Islands " means the territory of the Virgin
11
Islands as referred to in the Virgin Islands Constitution Order
12
2007;
13
(c)
the term "competent authority" means in the case of Australia, the
14
Commissioner of Taxation or an authorised representative of the
15
Commissioner and, in the case of the British Virgin Islands, the
16
Financial Secretary or a person or authority designated by the
17
Financial Secretary in writing;
18
(d)
the term "Contracting Party" means Australia or the British Virgin
19
Islands, as the context requires;
20
(e)
the term "national" means
21
22
(i) in relation to Australia , any person who is an Australian
23
citizen;
24
25
Schedule 1 International Tax Agreements Act 1953
8 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
(ii) in relation to the British Virgin Islands, any person who
1
belongs to the British Virgin Islands or is a permanent
2
resident of the British Virgin Islands;
3
4
(f)
the term "person", wherever used, refers to an individual;
5
(g)
the term "tax" means Australian tax or British Virgin Islands tax as
6
the context requires.
7
2
As regards the application of this Agreement at any time by a
8
Contracting Party, any term not defined therein shall, unless the context
9
otherwise requires, have the meaning that it has at that time under the law of
10
that Contracting Party, for the purposes of the taxes to which this Agreement
11
applies, with any meaning under the applicable tax laws of that Contracting
12
Party prevailing over a meaning given to the term under other laws of that
13
Contracting Party.
14
ARTICLE 4
15
RESIDENT
16
1
For the purposes of this Agreement, the term "resident of a Contracting
17
Party" means:
18
(a)
in the case of Australia, a person who is a resident of Australia for
19
the purposes of Australian tax; and
20
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 9
(b) in the case of the British Virgin Islands, a person who is liable to
1
pay tax under British Virgin Islands law.
2
2
A person is not a resident of a Contracting Party for the purposes of this
3
Agreement if the person is liable to tax in that Contracting Party in respect only
4
of income from sources in that Contracting Party.
5
3
Where by reason of the preceding provisions of this Article a person,
6
being an individual, is a resident of both Contracting Parties, then the person's
7
status shall be determined as follows:
8
(a)
the individual shall be deemed to be a resident only of the
9
Contracting Party in which a permanent home is available to that
10
individual; if a permanent home is available in both Contracting
11
Parties, or in neither of them, that individual shall be deemed to be
12
a resident only of the Contracting Party with which the individual's
13
personal and economic relations are closer (centre of vital
14
interests);
15
(b)
if the Contracting Party in which the individual has their centre of
16
vital interests cannot be determined, the individual shall be deemed
17
to be a resident only of the Contracting Party of which the
18
individual is a national;
19
(c)
if the individual is a national of both Contracting Parties or of
20
neither of them, the competent authorities of the Contracting
21
Parties shall endeavour to resolve the question by mutual
22
agreement.
23
Schedule 1 International Tax Agreements Act 1953
10 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
ARTICLE 5
1
GOVERNMENT SERVICE
2
1
(a) Salaries, wages and other similar remuneration, other than a pension
3
or retirement annuity, paid by a Contracting Party or a political
4
subdivision or a local authority thereof to an individual in respect of
5
services rendered to that Contracting Party or subdivision or authority
6
shall be taxable only in that Contracting Party.
7
(b) However, such salaries, wages and other similar remuneration shall
8
be taxable only in the other Contracting Party if the services are
9
rendered in that Contracting Party and the individual is a resident of
10
that Contracting Party who:
11
(i)
is a national of that Contracting Party; or
12
(ii) did not become a resident of that Contracting Party solely for
13
the purpose of rendering the services.
14
2
Notwithstanding the provisions of paragraph 1, salaries, wages and
15
other similar remuneration in respect of services rendered in connection with
16
any trade or business carried on by a Contracting Party or a political subdivision
17
or a local authority thereof may be taxed in accordance with the laws of a
18
Contracting Party.
19
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 11
ARTICLE 6
1
STUDENTS
2
Payments which a student or business apprentice, who is or was
3
immediately before visiting a Contracting Party a resident of the other
4
Contracting Party and who is temporarily present in the first-mentioned
5
Contracting Party solely for the purpose of their education or training, receives
6
for the purpose of their maintenance, education or training shall not be taxed in
7
that Contracting Party, provided such payments arise from sources outside that
8
Contracting Party.
9
ARTICLE 7
10
EXCHANGE OF INFORMATION
11
The competent authorities of the Contracting Parties shall exchange such
12
information as is foreseeably relevant for carrying out the provisions of this
13
Agreement. Information may be exchanged by the competent authorities for the
14
purposes of this Article in accordance with the provisions of the Agreement on
15
the Exchange of Information Relating to Taxes concluded by the Contracting
16
Parties (whether or not this Agreement, in whole or in part, forms part of the
17
domestic law of either Contracting Party).
18
Schedule 1 International Tax Agreements Act 1953
12 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
ARTICLE 8
1
ENTRY INTO FORCE
2
The Contracting Parties shall notify each other, in writing, through the
3
appropriate channel of the completion of their constitutional and legal
4
procedures for the entry into force of this Agreement. This Agreement shall
5
enter into force on the date of the last notification, and shall, provided an
6
Agreement for the Exchange of Information Relating to Taxes is in force
7
between the Contracting Parties, thereupon have effect:
8
(a)
in respect of Australian tax, for any year of income beginning on or
9
after 1 July in the calendar year next following the date on which
10
this Agreement enters into force; and
11
(b)
in respect of British Virgin Islands tax, for any year of income
12
beginning on or after 1 January in the calendar year next following
13
the date on which this Agreement enters into force.
14
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 13
ARTICLE 9
1
TERMINATION
2
1
This Agreement shall continue in force indefinitely, but either of the
3
Contracting Parties may, give to the other Contracting Party through the
4
appropriate channel written notice of termination
5
2
Such termination shall become effective:
6
(a)
in respect of Australian tax, in the year of income beginning on or
7
after 1 July in the calendar year next following that in which the
8
notice of termination is given;
9
(b)
in respect of British Virgin Islands tax, for any year of income
10
beginning on or after 1 January in the calendar year next following
11
that in which the notice of termination is given.
12
3
Notwithstanding the provisions of paragraph 1 or 2, this Agreement
13
shall, on receipt through the appropriate channel of written notice of termination
14
of the Agreement for the Exchange of Information Relating to Taxes between
15
the Contracting Parties, terminate and cease to be effective on the first day of
16
the month following the expiration of a period of six months after the date of
17
receipt of such notice.
18
Schedule 1 International Tax Agreements Act 1953
14 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
IN WITNESS WHEREOF the undersigned, being duly authorised
1
thereto by their respective Governments, have signed this Agreement.
2
3
DONE at London, this 27
th
day of October, 2008 in the English
4
language.
5
6
FOR THE GOVERNMENT OF
FOR THE GOVERNMENT OF
7
AUSTRALIA:
BRITISH VIRGIN ISLANDS:
8
Schedule 49--The Isle of Man agreement
9
Note:
See section 3.
10
11
AGREEMENT BETWEEN THE GOVERNMENT OF AUSTRALIA AND
12
THE GOVERNMENT OF THE ISLE OF MAN FOR THE ALLOCATION OF
13
TAXING RIGHTS WITH RESPECT TO CERTAIN INCOME OF
14
INDIVIDUALS AND TO ESTABLISH A MUTUAL AGREEMENT
15
PROCEDURE IN RESPECT OF TRANSFER PRICING ADJUSTMENTS
16
The Government of Australia and the Government of the Isle of Man
17
("the Parties"),
18
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 15
Recognising that the Parties have concluded an Agreement on the Exchange of
1
Information with Respect to Taxes, and
2
Desiring to conclude an Agreement for the allocation of taxing rights with
3
respect to certain income of individuals and to establish a mutual agreement
4
procedure in respect of transfer pricing adjustments,
5
Have agreed as follows:
6
ARTICLE 1
7
PERSONS COVERED
8
This Agreement shall apply to persons who are residents of one or both
9
of the Parties.
10
Schedule 1 International Tax Agreements Act 1953
16 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
ARTICLE 2
1
TAXES COVERED
2
1
The existing taxes to which this Agreement shall apply are:
3
(a)
in Australia, the income tax imposed under the federal law of
4
Australia;
5
(hereinafter referred to as "Australian tax").
6
(b)
in the Isle of Man, taxes on income or profits;
7
(hereinafter referred to as "Manx tax").
8
2
This Agreement shall also apply to any identical or substantially similar
9
taxes which are imposed after the date of signature of this Agreement in
10
addition to, or in place of, the existing taxes. The competent authorities of the
11
Parties shall notify each other within a reasonable period of time of any
12
substantial changes to the taxation laws covered by this Agreement.
13
3
This Agreement shall not apply to taxes imposed by states,
14
municipalities, local authorities or other political subdivisions, or possessions of
15
a Party.
16
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 17
ARTICLE 3
1
DEFINITIONS
2
1
For the purposes of this Agreement, unless the context otherwise
3
requires:
4
(a)
the term "Australia", when used in a geographical sense, excludes
5
all external territories other than:
6
(i)
the Territory of Norfolk Island;
7
(ii) the Territory of Christmas Island;
8
(iii) the Territory of Cocos (Keeling) Islands;
9
(iv) the Territory of Ashmore and Cartier Islands;
10
(v) the Territory of Heard Island and McDonald Islands; and
11
(vi) the Coral Sea Islands Territory,
12
and includes any area adjacent to the territorial limits of Australia
13
(including the Territories specified in this subparagraph) in respect
14
of which there is for the time being in force, consistently with
15
international law, a law of Australia dealing with the exploration
16
for or exploitation of any of the natural resources of the seabed and
17
subsoil of the continental shelf;
18
Schedule 1 International Tax Agreements Act 1953
18 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
(b)
the term "competent authority" means, in the case of Australia, the
1
Commissioner of Taxation or an authorised representative of the
2
Commissioner and, in the case of the Isle of Man, the Assessor of
3
Income Tax or an authorised delegate;
4
(c)
the term "Isle of Man" means the island of the Isle of Man;
5
(d)
the term " Party" means Australia or Isle of Man, as the context
6
requires;
7
(e)
the term "national", in relation to a Party, means any individual
8
possessing the nationality or citizenship of that Party;
9
(f)
the term "person" includes an individual, a company and any other
10
body of persons;
11
(g)
the term "tax" means Australian tax or Manx tax, as the context
12
requires; and
13
(h)
the term "transfer pricing adjustment" means an adjustment made
14
by the competent authority of a Party to the profits of an enterprise
15
as a result of applying the domestic law concerning taxes referred
16
to in Article 2 of that Party regarding transfer pricing.
17
2
As regards the application of this Agreement at any time by a Party, any
18
term not defined therein shall, unless the context otherwise requires, have the
19
meaning that it has at that time under the law of that Party, for the purposes of
20
the taxes to which this Agreement applies, with any meaning under the
21
applicable tax laws of that Party prevailing over a meaning given to the term
22
under other laws of that Party.
23
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 19
ARTICLE 4
1
RESIDENT
2
1
For the purposes of this Agreement, the term "resident of a Party"
3
means:
4
(a)
in the case of Australia, a person who is a resident of Australia for
5
the purposes of Australian tax; and
6
(b)
in the case of the Isle of Man, a person who is a resident for the
7
purposes of Manx tax.
8
2
A person is not a resident of a Party for the purposes of this Agreement
9
if the person is liable to tax in that Party in respect only of income from sources
10
in that Party.
11
3
Where by reason of the preceding provisions of this Article a person,
12
being an individual, is a resident of both Parties, then the person's status shall
13
be determined as follows:
14
(a)
the individual shall be deemed to be a resident only of the Party in
15
which a permanent home is available to that individual; if a
16
permanent home is available in both Parties, or
17
Schedule 1 International Tax Agreements Act 1953
20 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
in neither of them, that individual shall be deemed to be a resident
1
only of the Party with which the individual's personal and
2
economic relations are closer (centre of vital interests);
3
(b)
if the Party in which the individual has their centre of vital interests
4
cannot be determined, the individual shall be deemed to be a
5
resident only of the Party of which the individual is a national;
6
(c)
if the individual is a national of both Parties or of neither of them,
7
the competent authorities of the Parties shall endeavour to resolve
8
the question by mutual agreement.
9
4
Where by reason of paragraph 1 a person other than an individual is a
10
resident of both Parties, then it shall be deemed to be a resident only of the
11
Party in which its place of effective management is situated.
12
ARTICLE 5
13
PENSIONS AND RETIREMENT ANNUITIES
14
1
Pensions (including government pensions) and retirement annuities paid
15
to an individual who is a resident of a Party shall be taxable only in that Party.
16
However, pensions and retirement annuities arising in a Party may be taxed in
17
that Party where such income is not subject to tax in the other Party.
18
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 21
2
The term "retirement annuity" means:
1
(a)
in the case of Australia, a superannuation annuity payment within
2
the meaning of the taxation laws of Australia;
3
(b)
in the case of the Isle of Man, an annuity payment within the
4
meaning of the taxation laws of the Isle of Man; and
5
(c)
any other similar periodic payment agreed upon by the competent
6
authorities.
7
ARTICLE 6
8
GOVERNMENT SERVICE
9
1
(a) Salaries, wages and other similar remuneration, other than a pension
10
or retirement annuity, paid by a Party or a political subdivision or a
11
local authority thereof to an individual in respect of services rendered
12
to that Party or subdivision or authority shall be taxable only in that
13
Party.
14
(b) However, such salaries, wages and other similar remuneration shall
15
be taxable only in the other Party if the services are rendered in that
16
Party and the individual is a resident of that Party who:
17
(i)
is a national of that Party; or
18
Schedule 1 International Tax Agreements Act 1953
22 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
(ii) did not become a resident of that Party solely for the purpose of
1
rendering the services.
2
2
Notwithstanding the provisions of paragraph 1, salaries, wages and
3
other similar remuneration in respect of services rendered in connection with
4
any trade or business carried on by a Party or a political subdivision or a local
5
authority thereof may be taxed in accordance with the laws of a Party.
6
ARTICLE 7
7
STUDENTS
8
Payments which a student or business apprentice, who is or was
9
immediately before visiting a Party a resident of the other Party and who is
10
temporarily present in the first-mentioned Party solely for the purpose of their
11
education or training, receives for the purpose of their maintenance, education
12
or training shall not be taxed in that Party, provided such payments arise from
13
sources outside that Party.
14
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 23
ARTICLE 8
1
MUTUAL AGREEMENT PROCEDURE IN RESPECT OF TRANSFER
2
PRICING ADJUSTMENTS
3
1
Where a resident of a Party considers the actions of the other Party
4
results or will result in a transfer pricing adjustment not in accordance with the
5
arm's length principle, the resident may, irrespective of the remedies provided
6
by the domestic law of those Parties, present a case to the competent authority
7
of the first-mentioned Party. The case must be presented within three years of
8
the first notification of the adjustment.
9
2
The competent authorities shall endeavour to resolve any difficulties or
10
doubts arising as to the application of the arm's length principle by a Party
11
regarding transfer pricing adjustments. They may also communicate with each
12
other directly for the purposes of this Article.
13
14
Schedule 1 International Tax Agreements Act 1953
24 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
ARTICLE 9
1
EXCHANGE OF INFORMATION
2
The competent authorities of the Parties shall exchange such
3
information as is foreseeably relevant for carrying out the provisions of this
4
Agreement. Information may be exchanged by the competent authorities for the
5
purposes of this Article in accordance with the provisions of the Agreement on
6
the Exchange of Information with Respect to Taxes concluded by the Parties
7
(whether or not this Agreement, in whole or in part, forms part of the domestic
8
law of either Party).
9
ARTICLE 10
10
ENTRY INTO FORCE
11
The Parties shall notify each other, in writing, through the appropriate
12
channel of the completion of their constitutional and legal procedures for the
13
entry into force of this Agreement. This Agreement shall enter into force on the
14
date of the last notification, and shall, provided an Agreement for the Exchange
15
of Information with Respect to Taxes is in force between the Parties, thereupon
16
have effect:
17
International Tax Agreements Act 1953 Schedule 1
International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009 25
(a)
in respect of Australian tax, for any year of income beginning on or
1
after 1 July in the calendar year next following that in which this
2
Agreement enters into force; and
3
(b)
in respect of the Isle of Man, for any year of income beginning on
4
or after 5 April in the calendar year next following that in which
5
this Agreement enters into force.
6
ARTICLE 11
7
TERMINATION
8
1
This Agreement shall continue in effect indefinitely, but either of the
9
Parties may give to the other Party through the appropriate channel written
10
notice of termination.
11
2
Such termination shall become effective:
12
(a)
in respect of Australian tax, in the year of income beginning on or
13
after 1 July in the calendar year next following that in which the
14
notice of termination is given;
15
(b)
in respect of Manx tax, for any year of income beginning on or
16
after 5 April in the calendar year next following that in which the
17
notice of termination is given.
18
Schedule 1 International Tax Agreements Act 1953
26 International Tax Agreements Amendment Bill (No. 1) 2009 No. , 2009
3
Notwithstanding the provisions of paragraph 1 or 2, this Agreement
1
shall, on receipt through the appropriate channel of written notice of termination
2
of the Agreement for the Exchange of Information with Respect to Taxes
3
between the Parties, terminate and cease to be effective on the first day of the
4
month following the expiration of a period of 6 months after the date of receipt
5
of such notice.
6
IN WITNESS WHEREOF the undersigned, being duly authorised
7
thereto by their respective Governments, have signed this Agreement.
8
DONE at LONDON, UNITED KINGDOM, this 29
th
day of
9
JANUARY, 2009, in duplicate in the English language.
10
FOR THE GOVERNMENT OF
FOR THE GOVERNMENT OF
11
AUSTRALIA:
THE ISLE OF MAN:
12

 

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