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Edited version of your private ruling
Authorisation Number: 1012393093835
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Ruling
Subject: Royalties, payment to foreign residents
Questions at issue
In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided.
The ruling concerned the following:
The taxpayer is requesting a ruling whether subsection 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936) regarding royalty applies under their current circumstances.
The taxpayer is requesting a ruling whether section 12-315 of Schedule 1 to the Taxation Administration Act 1953 (TAA 1953) applies under their current circumstances.
The Commissioner has ruled that:
No, subsection 6(1) of the ITAA 1936 will not apply to the current circumstances.
No, section 12-315 of the TAA 1953 will not apply to the current circumstances.