The OECD has just published its proposed consolidated text, which shows how to read modified articles. It will probably take us some more time before we have any clarification on the final formulation and application based on DBA-for-DBA. This shows the continued commitment of both countries to oppose international tax evasion practices. Australia has tax agreements with many countries around the world. Under the agreements, certain forms of income are exempt or eligible for reduced rates. These include royalties, dividends and capital gains. Other countries could ratify the treaty and subsequently amend their DTAs. .