Published on 23 May 19
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
- significance and meaning of “source”
- source principles relating to certain types of income
- relevance of DTAs and MLI
- Commissioner of Taxation v RCF IV LP  FCAFC 51 (“RCF IV”)
- treaty source rule and Satyam Computer Services Limited v Commissioner of Taxation  FCAFC 172 (“Satyam”).