(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. .