ITAA 1936 s 17A(4) of the International Tax Agreements Act 1953 (the Agreements Act) does not exclude the payment from section 128B

Income tax: withholding tax and related implications for a non-resident head lessor or hire-purchase provider of substantial equipment where the equipment is obtained by another non-resident entity that subleases, subprovides or leases it for use in Australia

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?