20 Dec 077 Withholding tax: sublease by non-resident head lessor of substantial equipment for use in Australia - TR 2007/11This final Taxation Ruling was issued on 19 December 2007. It was previously released in draft form as TD 2007/D12: see 2007 TAXVINE No 22 (10) (8 June 2007). Its full title is "Income tax: withholding tax and related implications for a non-resident head lessor or hire-purchase provider of substantial equipment where the equipment is obtained by another non-resident entity that subleases, subprovides or leases it for use in Australia".
In considering the tax implications of the stated arrangement, the Ruling examines the implications of the Full Federal Court decision in McDermott Industries (Aust) Pty Ltd v. FCT  FCAFC 67.
For a copy of TR 2007/11, go here