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Australia, Marshall Islands Sign Tax Agreements

by Mary Swire,, Hong Kong

19 May 2010

Australia’s Assistant Treasurer, Nick Sherry, has announced that Australia has signed a bilateral tax treaty with the Marshall Islands for the exchange of tax information (TIEA), together with a separate agreement to help to resolve transfer pricing disputes.

“Securing this latest agreement further expands Australia's TIEA network – which is growing rapidly," Sherry said. “The Marshall Islands is the 25th jurisdiction to sign such an agreement with Australia.”

"The government welcomes the Marshall Islands as a partner in the important work of preventing offshore tax avoidance and evasion,” he added. “The signing of this agreement demonstrates the Marshall Islands' commitment to international tax standards."

In addition to the TIEA, Australia and the Marshall Islands signed an Additional Benefits Agreement (ABA). The ABA will establish an administrative mechanism to resolve transfer pricing disputes between taxpayers and the revenue authorities of Australia and the Marshall Islands, and eliminate the double taxation of certain income derived by retirees, government employees and students.

The new arrangements will also assist the Marshall Islands revenue authority to implement the TIEA through the provision of technical assistance and training to be delivered by the Australian Taxation Office.

These agreements will enter into force after both countries have completed their relevant domestic requirements.

This comprehensive report in our Intelligence Report series examines the global and national landscapes in which companies can use transfer pricing to improve their after-tax returns, including summaries of recent developments in design of the corporate supply train, the usefulness of 'offshore' in international corporate tax planning, and a section covering the spread of DTAAs and CFC laws. It is available in the Lowtax Library at and a description of the report can be seen at
TAGS: tax | offshore confidentiality | tax information exchange agreement (TIEA) | tax avoidance | law | Australia | Marshall Islands | offshore | agreements | transfer pricing

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