The Australian Taxation Office (ATO) has published the synthesized text of the 1999 income tax treaty with the Slovak Republic as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text represents the shared understanding of the competent authorities on the modification made to the treaty by the MLI. The sole purpose of the text is to facilitate understanding of the application of the MLI to the treaty and it does not constitute a source of law.
The provisions of the MLI (other than Article 16 Mutual Agreement Procedure) have effect with respect to the treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2019; and
- with respect to all other taxes levied by each Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 July 2019.
Article 16 of the MLI (Mutual Agreement Procedure) has effect with respect to the treaty for a case presented to the competent authority of a Contracting State on or after 1 January 2019, except for cases that were not eligible to be presented as of that date under the treaty prior to its modification by the MLI, without regard to the taxable period to which the case relates.
Click the following link for the ATO's webpage on the BEPS MLI for more information.