Private ruling: International issues
Date of advice: 27 November 2025
Published: 12 January 2026
Ruling period: 1 July 20xx to 30 June 20xx | This scheme commenced on: | 1 July 20xx

Ruling: Q1: Does Article 8 of double tax agreement with Country X (DTA) apply to the income derived by non-resident ABC Co from the Payment such that the income is not assessable income for ABC Co under subsection 6-5(3) of the Income Tax Assessment Act 1997 ? | A1: Yes. | Q2: Does Article 8 of the DTA apply to the income received by ABC Co for marketing support from the Agreement such that the income is not assessable income for ABC Co under subsection 6-5(3) of the ITAA 1997? | A2: Yes.