On 9 May 2017, the Australian Tax Office (ATO) published brief guidance on indirect Australian real property interests for the purpose of foreign resident capital gains tax withholding. Subject to certain conditions, the 10% non-final withholding tax applies for Australia property disposals under contracts entered into from 1 July 2016. This includes disposals of indirect Australian real property interests, which are membership interests in an entity that, subject to exclusions, satisfies tw…