The Australian Taxation Office (ATO) has published guidance on the application of the straddle holding period rule for dividend withholding tax under Australia's tax treaties.
---
Straddle holding period rule
Under particular tax treaties, including some of those modified by Article 8 of the Multilateral Instrument, non-portfolio intercorporate dividends may become eligible for reduced withholding tax rates if the beneficial owner of the dividend satisfies the straddle holding period ru…