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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 CTA
Photo of author, Spyros KOTSOPOULOS Spyros Kotsopoulos, CTA, is a Tax Advisory Partner at Deloitte Touche Tohmatsu in Sydney. Spyros is involved with clients in the middle market area that that extend from high wealth family groups thorough to small cap listed entities. The emphasis of Spyros’s advisory work is on tax structuring, M&A (including tax due diligence) strategic tax planning and tax controversy/audit. This involves taking a proactive approach when assisting clients in dealing with their tax affairs. - Current at 18 June 2018
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