In addition to an OECD mutual assistance clause, Switzerland and Australia have agreed, for example, that both countries can levy a transfer tax of up to 5% on gross dividends from essential interest (compared to 15% currently); within a listed group, dividends are totally exempt from withholding tax under certain conditions. In addition, no withholding tax is levied on dividends and interest paid to pension funds. Interest paid to financial institutions is also exempt from withholding tax. The withholding tax rate for royalties will be reduced from 10% to 5%. In addition, rents are no longer considered as royalties, which corresponds to an exemption from withholding tax. An arbitration clause was also included in the agreement. If sections 23AH or 23AJ of itAA 1936) are exempt from Australian tax, these provisions remain eligible for exemption from Australian tax. In the absence of double taxation in these cases, the form of credit of the discharge is not relevant. 2.6 A minor amendment is also made to include a reference to section 5A. Section 5A provides that a number of earlier agreements retain the force of res judicata. The note informs the reader that certain earlier agreements may remain in force under other provisions of the Act, i.e. the 1980 Swiss Agreement under Article 11E.
[Annex 1, point 5, 1953 Agreements Act 1953, subsection 3AAA (1)] 1.252 It is however necessary to impose a method of reducing double taxation for other categories of income, profits or profits which remain taxable in both countries under the Swiss Convention. . . .