On 27 June 2006, the Australian Taxation Office (ATO) released for discussion a draft taxation ruling TR 2007/D5 in which it took a position that payments for an assignment of copyright, including partial assignments, are royalties and therefore may be subject to royalty withholding tax.
The Draft Ruling mentions that the ATO became aware of copyright assignment arrangements with non-residents with an aim to reduce or avoid royalty withholding tax which would o…