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Edited version of your private ruling
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Ruling
Subject: Permanent establishment
Question
Is a payment made by the Australian entity to the Overseas entity under an agreement for the staging of additional events, to the extent that it is equal to half of the receipts from certain sales and rights from the proposed events to be held in Australia, assessable income in terms of subsection 6-5(3) of the Income Tax Assessment Act 1997 (ITAA 1997) on the premise that the Overseas entity will not have a 'permanent establishment' in Australia as defined in X Article of the Treaty?
Answer
No. On the premise that the Overseas Entity will not have a 'permanent establishment' in Australia as defined in X Article of the Treaty, a payment made by the Australian Entity to the Overseas Entity under an agreement for the staging of additional events, to the extent that it is equal to half of the receipts from certain sales and rights from the proposed events to be held in Australia, is not assessable income in terms of subsection 6-5(3) of the ITAA 1997.