Firstly, draft TR 2024/D1 provides the ATO’s views on when cross-border payments related to software arrangements are properly regarded as royalties and thus subject to Australian royalty withholding tax. Generally, the characterisation of ...
The Commissioner made determinations under the transfer pricing rules in Division 13 of the Income Tax Assessment Act 1936 (ITAA36) and Subdivision 815-A of the Income Tax Assessment Act 1997 (ITAA97) that STAI had obtained a “transfer pricing benefit”. The determinations substituted...
“These actions form a critical part of our response to the revelations of unacceptable breaches of confidential information in parts of the firm’s tax practice,” the firmsaidin a media release. The string of confidentiality breaches in its tax practice began many years ago....