Private ruling: Income tax - royalties
Date of advice: 5 April 2023
Published: 29 May 2023

Ruling: Q1: Are payments, or part thereof, made by HeadCo or SubCo under the A Agreement, B Agreement and C Agreement, referred to in fact X of the relevant facts and circumstances of the Ruling, 'royalties' as defined in subsection 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936)? | A1: Yes. | Q2: Are payments, or part thereof, made by HeadCo or SubCo under the D Agreement, referred to in fact X of the relevant facts and circumstances of the Ruling, 'royalties' as defined in subsection 6(1) of the ITAA 1936? | A2: Yes.