The Australian Taxation Office released on 9 April 2008, for discussion a Draft Taxation Ruling TR 2008/D3 dealing with the taxation treatment of ship and aircraft leasing profits under the ships and aircraft articles of Australia's tax treaties.
The Draft Ruling clarifies the taxation implications under each of Australia tax treaties, including Airline Profit Agreements. In particular, the Draft Ruling aims to clarify in what circumstances Australia is allocated a righ…