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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:

Author Photo - Spyros Kotsopoulos CTA
Spyros Kotsopoulos CTA
Spyros is a Tax Consulting Partner at Deloitte Touche Tohmatsu in Sydney. Spyros is involved with clients in the middle market area that have a focus on using e-commerce in their business. The emphasis of Spyros’s work is on tax structuring and strategic tax planning. This involves taking a proactive approach when assisting clients who are seeking to expand their activities offshore and take advantage of the new opportunities offered via the internet. Current at 02 June 2014 Click here to expand/collapse more articles by Spyros KOTSOPOULOS.
 

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