International Tax Agreements Act 1953

Where a company is not a resident of Australia but, for the purposes of a law of a country with which, or with the government of which, an agreement has been made (being a law which imposes foreign tax), is resident in that other country, a dividend paid by the company shall, for the purposes of the agreement, be deemed to be derived from a source in that country.

Subsection (1) does not limit the operation of a provision of an agreement by virtue of which a dividend is deemed to be derived from a source outside Australia.