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1 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

Yes. Question 2 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? Answer Yes.

of the Ruling, 'royalties' as defined in subsection 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936)?