All DBAs include the POP as a low-cost dispute resolution mechanism. As a general rule, the POP only provides for the relevant authorities to work to resolve the problem. However, some POPs provisions are supplemented by arbitration provisions to eliminate cases where the relevant authorities are unable to reach an agreement. With the intention of concluding an agreement on the elimination of double taxation with respect to income tax, without the possibility of non-taxation or reduced taxation by tax evasion or evasion (including through contractual shopping agreements to obtain facilities provided in this agreement for the indirect benefit of residents of third countries), the DBAs will benefit from a reduction in double taxation than is provided by national legislation. The agreement enters into force in accordance with Article 28 of the agreement. The agreements under the agreement were negotiated with the Government of the People`s Republic of China for one or more of the objectives of Section BS 1(2) of the Income Tax Act 2007. The 1986 double taxation (China) decision (RS 1986/314) was revoked on the date covered by Article 28, paragraph 1 of the agreement, on the effective date of the agreement. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other State party where the objection appears to be well founded and it is unable to find a satisfactory solution to resolve the matter by mutual agreement with the competent authority of the other State party, in order to avoid tax evasion that is not in accordance with the agreement. Any agreement reached will be implemented in the domestic law of the States Parties, regardless of the time frame. 4. The competent authorities of the contracting states may communicate directly with each other in order to reach an agreement in accordance with the preceding paragraphs. Article 13, paragraph 6, of the agreement was introduced to avoid double taxation of capital gains on outgoing residents.

Under the Australian CGT scheme, a person who no longer has a home in Australia is normally taxed on unrealized profits of CGT assets held on that date, with assets other than taxable assets. However, a person who ceases to have an Australian-based tax may choose, at the time of departure, to either pay taxes (based on the difference between the market value of the non-taxable Australian assets at the time of departure and the cost base of those assets), or to defer tax on a possible profit until the effective disposal of these non-taxable Australian assets. In both cases, this person is treated as if he had disposed of tax-free Australian assets and acquired it at fair value if, under New Zealand tax law (which currently does not impose capital gains), he is no longer resident in Australia.