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Australian Federal Court Grants Stay in Oracle Royalty Tax Dispute to Allow MAP Under Tax Treaty with Ireland

|Treaty Development|Australia-Ireland
Australia-Ireland

The Full Federal Court of Australia recently delivered its judgment in Oracle Corporation Australia Pty Ltd v Commissioner of Taxation 025] FCAFC 145, allowing Oracle’s appeal and granting a stay of domestic tax proceedings. The case concerns payments made by Oracle Australia to Oracle Ireland under intra-group software licensing agreements. The Australian Taxation Office (ATO) classified thes…

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