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Direct income tax paper

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DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

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
Photo of author, Spyros KOTSOPOULOS
Click here to expand/collapse more articles by Spyros KOTSOPOULOS.

 

This was presented at Cloud Computing .

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Individual sessions

Introduction to cloud computing

Author(s):  Stuart JOHNSTON

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A practical guide to risk issues in cloud computing

Author(s):  Nick ABRAHAMS

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Direct income tax

Author(s):  Spyros KOTSOPOULOS

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Transfer pricing and the cloud - What do multinationals need to consider?

Author(s):  Geoffrey GILL

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GST and cloud computing

Author(s):  Mark TAFFT

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Cloud computing practical case studies

Author(s):  Simon THORP

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