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The Australian Tax Office and New Zealand Inland Revenue are in the process of formalising a practical administrative approach for non-individual dual residents affected by Article 4(1) of the Multilateral Convention (MLI).
Under Article 4(1) of the MLI, which is designed to address tax avoidance arrangements, non-individual taxpayers that are dual residents need to apply to either Competent Authority for a determination of their residency for tax treaty purposes.
The administrative approach will seek to provide certainty and minimise compliance costs for non-individual dual residents that meet certain eligibility criteria.
We will publish the administrative approach once it is finalised, including eligibility criteria and any additional guidance.
For more information see the note on Competent Authority determination under Article 4(1) of the MLI.
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