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A former Australian resident who has been taxed on the unrealised gains upon departure from Australia, and who becomes a New Zealand resident, may elect to be treated for New Zealand taxation purposes as having, immediately before ceasing to be a resident of Australia, alienated and reacquired the property for an amount equal to its fair market value at that time. Employment income paid in respect of certain short term visits are taxable only in the country of residence of the employee where the remuneration is borne by a permanent establishment of the employer in the employees country of residence, or is paid in respect of a secondment. Application of the Convention to fiscally transparent entities, Model Tax Convention on Income and on Capital, Eligibility for the treaty benefits will also be subject to the application of the respective anti-avoidance measures contained in the specific Article (in this example, paragraph 9 of Article 10 (, As such, in this example, the dividend income would be eligible for the benefits of the Convention. 5.26 Both countries have particular policy objectives to achieve in updating the tax treaty and the end result ultimately represents compromises necessary to achieve a mutually acceptable agreement. 5.25 A new tax treaty would be largely based on the current OECD Model, with some mutually agreed variations reflecting the economic, legal and cultural interests of the two countries. Assistance must therefore be provided as regards a revenue claim owed to either country by any person, whether or not a resident of Australia or NewZealand. This will be the case, notwithstanding that one or more of the participants in the corporate limited partnership is not a resident of Australia and irrespective of whether New Zealand, under its domestic law, would tax the income in the hands of the Australian corporate limited partnership or in the hands of the partners. [Article 12, subparagraph3f)], 2.239 As in the case of dividend or interest income, it is specified that the withholding tax rate limitation does not apply to royalties paid in respect of property or rights which are effectively connected with a permanent establishment in the country in which the income is sourced. 5.59 While the existing New Zealand treaty already has a services provision in that it permits a country to tax professional services in the country where they are performed where the individual is present for a period of 183 days in any twelve months (in the Independent Personal Services Article), it does not provide an exemption for short-term stays of five days or less.