ATO issues draft ruling on software and royalty withholding tax – 25 June 2021

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ATO issues draft ruling on software and royalty withholding tax – 25 June 2021

Tax insights

On 25 June 2021, the Australian Taxation Office published Draft Taxation Ruling TR 2021/D4, which addresses the circumstances in which receipts from the licensing and distribution of software will be royalties as defined in Australian domestic law. The Draft Ruling provides guidance to software owners, software distributors and end users of software, and sets out the ATO’s views of the tax law applicable to three software distribution models:

  • Packaged software
  • Digital downloading of software, and
  • Cloud computing arrangements.
ATO issues draft ruling on software and royalty withholding tax – 25 June 2021
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