Australian Court Holds Source of Income Provisions in India Tax Treaty Allows Service Payments to be Treated as Royalty Income Assessable in Australia
Australia's Federal Court has published an 11 October 2018 decision of the Full Court on whether service payments received by an Indian company from its Australian clients that are royalties for the purposes of Article 12 (Royalties) of the 1991 Australia-India tax treaty but are not otherwise royalties as defined under Australian law, may be considered assessable income in Australia.
The cas…
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