The Australian Taxation Office has published for public comment Draft Taxation Ruling TR 2021/D4 Income tax: royalties - character of receipts in respect of software, which provides guidance on whether amounts received in respect of software are royalties and are not royalties. The ruling replaces Taxation Ruling TR 93/12 Income tax: computer software, and when finalized, will apply both before and after its date of issue. Taxpayers that rely on TR 2021/D4 reasonably and in good faith will n…