A joint professional body submission sent to the ATO in relation to TD 2007/D11: Income tax: will the hire of substantial equipment in Australia under a hire-purchase agreement creat a deemed permanent establishment for a Singaporean resident hirer under Article 4(3)(b) of the tax treaty between Australia and Singapore as a result of the decision in McDermott Industries (Aust) Pty Ltd v. Federal Commissioner of Taxation {2005} FCAFC 67? and TD 2007/D12: Income tax: is a non-resident head lessor of substantial equipment liable for royalty withholding tax under subsection 128B(5A) of the Income Tax Assessment Act 1936 on lease payments it receives from a Singaporean resident who subleases that same equipment to an entity which operates in Australia?
maintenance