Miscellaneous 2022

ATO Draft Ruling on Character of Software Receipts

Source: Victoria

Published Date: 25 Aug 2022

 

The ATO's draft ruling on royalties and the character of receipts in relation to software represents a departure from its historical approach in Taxation Ruling 93/12, which could have significant impact on businesses that are using or distributing software.

This presentation covers:

  • Potential risks associated with different business models involving the use of software
  • Interaction between the ATO's proposed approach and the legal lens around copyright
  • Implications for transfer pricing analyses involving software distributors
  • Potential approaches to apportionment of payments between the amounts for software copyright vis-à-vis amounts to secure other rights
  • The likely impact on the assessment and collection of withholding taxes

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Individual Session

ATO draft ruling on the character of receipts relating to software: To withhold or not to withhold?

Author(s): Chris Ferguson

Details

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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Miscellaneous 2022

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