Legislation

ITAA 1936 s 17A(5) of the International Tax Agreements Act 1953 (ITAA 1953) provides that where a payment does not fall within the meaning of a royalty under the agreements, then it will not be subject to PAYG withholding despite it being a royalty under section 6(1)

ATO documents that consider ITAA 1936 s 17A(5) of the International Tax Agreements Act 1953 (ITAA 1953) provides that where a payment does not fall within the meaning of a royalty under the agreements, then it will not be subject to PAYG withholding despite it being a royalty under section 6(1)