Royalty classification of software payments: remittances for software purchases are not treated as royalty under established precedent. Where distribution agreements or End User License Agreements do not grant any proprietary interest or a right to use copyright, payments for acquiring ... Summary
Royalty classification of software payments: remittances for software purchases are not treated as royalty under established precedent.
Where distribution agreements or End User License Agreements do not grant any proprietary interest or a right to use copyright, payments for acquiring computer software are not to be characterised as royalty; this conclusion follows controlling precedent and DTAA considerations and renders an Assessing Officer's contrary classification inconsistent with the correct legal interpretation.
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TaxTMI 
TaxTMI 
