ATO Publishes Final Taxation Ruling and Draft Guidance on Software Royalties

The Australian Taxation Office (ATO) has announced the publication of:

• Final Taxation Ruling (TR) 2026/2 Income tax: royalties – character of payments in respect of software and intellectual property rights; and
• Expanded draft Practical Compliance Guideline (PCG) 2026/D4: Royalty characterisation of payments relating to intermediation or distribution arrangements – ATO compliance approach.

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Software royalties: final taxation ruling and draft guidance

Software and tech businesses: …