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Direct income tax presentation

Published on 24 Oct 12 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation 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 is a Tax Advisory Partner at Deloitte in Sydney with over 25 years experience. Spyros advises clients ranging from high wealth family groups, large corporate groups and private equity, and is mindful of the specific needs of the commercial interests of each of these stakeholders when providing tax advice. The emphasis of Spyros’ advisory work is on tax structuring, M&A transaction services (including pre-IPO restructures, tax due diligence and review of tax indemnities and warranties), strategic tax planning and tax controversy/audit. Spyros has advised clients involved in financial services, funds management, property and construction, and professional services. - Current at 16 June 2022
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This was presented at Cloud Computing .

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