5.21 Although the current tax treaty provides a good level of protection against double taxation and the prevention of tax evasion, it is, in many respects, outdated and no longer adequately reflects the current policy and practice of Australian or New Zealand tax treaties. 2.260 In the event that the application of this Article would result in the taxation of a product or profit in both States, the country in which the person who has the income or profit is resident (as provided for in Article 4 (resident) would be required, under Article 23 (elimination of double taxation), to tax twice the tax levied by the other country. 2.269 Accordingly, Australia would also have the right to tax that remuneration, in accordance with the ITAA`s 1997 general rule, which provides that a taxable person established in Australia remains subject to world income tax. . . .