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ARTICLE 2

U.S. Income Tax Treaty — australia tax treaty documents: aus.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Taxes Covered

(1) The existing taxes to which this Convention shall apply are:

(a) in the United States: the Federal income taxes imposed by the Internal Revenue Code, but excluding the accumulated earnings tax and the personal holding company tax; and

(b) in Australia; the Australian income tax, including the additional tax upon the undistributed amount of the distributable income of a private company.

(2) This Convention shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Convention in addition to, or in place of, the existing taxes. At the end of each calendar year, the competent authority of each Contracting State shall notify the competent authority of the other Contracting State of any substantial changes which have been made during that year in the laws of his State relating to the taxes to which this Convention applies or in the official interpretation of those laws or of this Convention.

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