ITAA 1936 s 13 and 14 of this Determination, payments of this nature will be royalties under subsection 6(1)

Income tax: is a non-resident head lessor of substantial equipment liable for royalty withholding tax under subsection 128B(5A) of the Income Tax Assessment Act 1936 on lease payments it receives from a Singaporean resident who subleases that same equipment to an entity which operates it in Australia?