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

  • Published By: Chris Ferguson
  • Published On:25 Aug 2022
  • Took place at:Crown Melbourne

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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.

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Miscellaneous 2022

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