Private ruling: Royalties, payment to foreign residents
Published: December 2012

Ruling: Questions at issue | In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided. | The ruling concerned the following: | The taxpayer is requesting a ruling whether subsection 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936) regarding royalty applies under their current circumstances. | The taxpayer is requesting a ruling whether section 12-315 of Schedule 1 to the Taxation Administration Act 1953 (TAA 1953) applies under their current circumstances. | The Commissioner has ruled that: | No, subsection 6(1) of the ITAA 1936 will not apply to the current circumstances. | No, section 12-315 of the TAA 1953 will not apply to the current circumstances.




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