ATO releases final software royalty ruling and guidance
Client alertThe ATO has released final guidance on the royalty characterisation of software distribution, intermediation and intellectual property arrangements through TR 2026/2 and draft PCG 2026/D4. The guidance clarifies when software-related payments may be treated as royalties and subject to royalty withholding tax, while introducing a practical compliance risk framework.
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10 min read
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11 Sep 2026
