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Direct income tax paper

Published on 24 Oct 12 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • differences between cloud and e-commerce
  • characterisation of payments made for cloud services- royalty v service
  • residency issues created by e-commerce and cloud operations from the perspective of the user of cloud services and the provider of such services
  • permanent establishment issues created by cloud /e-commerce
  • treaty and OECD views of cloud.

Author profile:

Spyros KOTSOPOULOS

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