EV 1052004050546currentnon-binding advice

Income tax - royalties

Non-binding edited private advice. This is an edited version of private advice the ATO gave to a specific taxpayer about their own circumstances. You cannot rely on it — it is not binding and provides no protection for anyone else (see PS LA 2008/4). Use it as a guide to the ATO’s thinking, not as authority.

1

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

2

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.

3

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