McDermott Industries (Aust) Pty Ltd v Commissioner of Taxation

• 1. Taxation
  2. › International taxation
  3. › Double taxation agreements
  4. › Australia-Singapore Agreement
  5. › Permanent establishment
  6. › Deemed permanent establishment
  7. › Substantial equipment used under contract with enterprise
  8. › Whether bare boat charter of barges created permanent establishment
  9. › Whether Article 4(1) constrains interpretation of Article 4(3)(b)
  10. › International Tax Agreements Act 1953 (Cth), Sch 5, Art 4(3)(b)
• 1. Taxation
  2. › International taxation
  3. › Double taxation agreements
  4. › Relationship between business profits article and royalties article
  5. › Whether charter fees for substantial equipment taxable as business profits or as royalties
  6. › International Tax Agreements Act 1953 (Cth), Sch 5, Art 5, Art 10
• 1. Taxation
  2. › International taxation
  3. › Double taxation agreements
  4. › Interpretation of treaties
  5. › Vienna Convention on the Law of Treaties
  6. › Whether words 'by, for or under contract with' express single complex idea or three alternatives

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