Australian Court Rules that Payments Made by an Australian Software Distributor to a Canadian Licensor are Subject to Royalty Withholding Tax

The Full Court of the Federal Court of Australia recently dismissed an appeal by an Australian software distributor concerning the treatment of payments to a Canadian software licensor as royalties subject to withholding tax. The dispute involved whether or not an exclusion provided for in the Australia-Canada tax treaty was applicable. The dismissal of the appeal effectively upheld an earlier …
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