Taxation Ruling

TR 93/12W

Income tax: computer software

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Notice of Withdrawal

Taxation Ruling TR 93/12 is withdrawn with effect from 1 July 2021.

1. TR 93/12 deals with the assessability of receipts in respect of software and the treatment of software as trading stock under subsection 70-10(1) of the Income Tax Assessment Act 1997.

2. TR 93/12 has been replaced by Draft Taxation Ruling TR 2021/D4 Income tax: royalties - character of receipts in respect of software which issued on 25 June 2021.

3. TR 2021/D4 deals with the circumstances in which receipts from the licensing and distribution of software will be royalties as defined in subsection 6(1) of the Income Tax Assessment 1936. Other matters contained within TR 93/12 are considered to be generally well understood and it is proposed to deal with them through guidance to be published on

Commissioner of Taxation
30 June 2021


You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).


ATO references:
NO NO 92/7688-2

ISSN: 2205-6122

Legislative References:
ITAA 25(1)
ITAA 26(f)

Case References:
Dyason and Ors v. Autodesk Inc and Anor
(1989) 96 ALR 57

FC of T v. Suttons Motors (Chullora) Wholesale Pty Ltd
85 ATC 4398
16 ATR 567

Toby Constructions Products Pty Ltd v. Computer Bar Sales Pty Ltd
(1983) 2 NSWLR 48

TR 93/12W history
  Date: Version: Change:
  13 May 1993 Original ruling  
  29 November 2006 Original ruling + note Repeal provision note
  24 June 2021 Interim withdrawal  
You are here 30 June 2021 Withdrawal