Royalties in Australian Tax and Treaties: From Source Rules to Withholding Tax and Elusive Intangibles
New
Journal
Country
Australia; International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 9/10
Document
This article examines the development of Australia’s taxation of cross-border royalties, from early source-based assessment to final withholding tax, and its interaction with tax treaties and OECD norms. It highlights how royalty classification has become a critical boundary between source-state taxation and non-taxation and identifies pressure points in recent case law.