(a) the concept of “income or profit” includes “profits”; Income or profits of a territory established in the United Kingdom arising from one or more of Sections 6 to 8 and 10 to 16 and 18 may be taxed in Australia and are considered to be from sources in Australia for the purposes of Australian law relating to its tax. 3. Income or profits generated by a person established in a Contracting State arising from the sale of ships or aircraft operated in international traffic or of assets (other than immovable property) related to the operation of such ships or aircraft shall be taxable only in that Contracting State. Members of a partnership may be taxed in their country of residence on their individual shares in the income or profits of the partnership, even if the partnership is treated as a taxable unit under the law of the other country (Article 24). The Convention shall enter into force on the day of subsequent notification by each country of the conclusion of its legislative procedures. It will enter into force in the United Kingdom on 1 July next year after the date of entry into force, corporation tax on 1 April following that date and, as a general rule, capital gains tax and income tax from 6 April following that date. It enters into force in Australia on 1 July following the date of entry into force of the withholding tax, in respect of the ancillary services tax on 1 April following that date and for other Australian taxes on 1 July in force after that date (Article 29). The date of entry into force will be published in due course in the London, Edinburgh and Belfast Gazettes. 4. Enterprises of a Contracting State the capital of which is whote or partly owned or controlled directly or indirectly by one or more residents of the other Contracting State may not be subject in the first-mentioned State to taxation or a requirement which is different or heavier or heavier than the taxation and related requirements to which other similar enterprises of the First State in similar circumstances are or may be subject.
Every double taxation treaty is different, although many very similar guidelines follow, even if the details are different. .