In the McDermott Industries case the Full Federal Court held that a company, Chartering Company Singapore Pty Ltd, a resident of Singapore, was deemed under Article 4(3)(b) of the Singapore/Australia Double Tax Agreement to have a permanent establishment in Australia and to carry on business through that permanent establishment by virtue of it having chartered barges to McDermott Industries (Aust) Pty Ltd for use by it in its business of marine construction. This decision highlights a number of issues for taxpayers.
maintenance