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.