Law Council of Australia

Business Law Section

Draft Taxation Ruling TR 2024/D1 - Income tax: royalties - character of payments in respect of software and intellectual property rights

The Taxation Committee and the Intellectual Property Committee of the Business Law Section of the Law Council of Australia (the Committees) made a submission on Draft Taxation Ruling TR 2024/D1, which considers when amounts paid under software arrangements are royalties under section 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936) and Australia’s tax treaties (Draft Ruling).

The Committees make the following comments in relation to the Draft Ruling:

  1. Copyright laws
  2. Software as a service (SaaS)
  3. OECD Commentary—software distributors
  4. Simple use
  5. Examples

Read the full submission below.


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