The Resource Computer software transactions and the income tax definition of a royalty

Computer software transactions and the income tax definition of a royalty

Label
Computer software transactions and the income tax definition of a royalty
Title
Computer software transactions and the income tax definition of a royalty
Creator
Subject
Language
eng
Summary
The New Zealand Inland Revenue has adopted the OECD's and the United States Treasury's analyses for the tax treatment of computer software transactions. The central argument of this article is that the current practice of Inland Revenue is not in accordance with New Zealand law. In particular, this article focuses on the policy set out in Inland Revenue's 2003 Interpretation Guideline which states that a payment made for computer software is not a royalty and therefore is not subject to non-resident wihholding tax (NRWT). The argument advanced in this article is that this policy is not in accordance with New Zealand copyright law and that in a variety of common circumstances such payments (as a matter of law) constitute a royalty and should therefore be subject to NRWT. This article is not suggesting that Inland Revenue enforce this tax in its current form or that it deviate from current international practice; rather that the law and current international practice be brought into line
Citation source
In: New Zealand journal of taxation law and policy. - Wellington. - Vol. 20 (2014),
http://library.link/vocab/creatorName
Hullah, F
Geographic coverage
Pacific Islands
Language note
English
http://library.link/vocab/subjectName
  • software
  • royalties
  • withholding tax
  • copyright
Label
Computer software transactions and the income tax definition of a royalty
Instantiates
Publication
Label
Computer software transactions and the income tax definition of a royalty
Publication

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