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Australia: Guidance on evidencing income tax treaty residency in arrangements involving fiscally transparent entities

Guidance for the ATO’s Private Capital Program

june 12, 2026

The Australian Taxation Office (ATO) released guidance for its Private Capital Program on how to evidence income tax treaty residency in arrangements involving fiscally transparent entities (FTEs).

The guidance encourages early and open engagement when arrangements involve FTEs and income tax treaty benefit claims.

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