Acting U.S. Treasury Deputy Assistant Secretary (International Tax Affairs), Scott Levine, has sent a letter dated 5 April 2024 to the Australian Treasury First Assistant Secretary, Marty Robinson, highlighting issues with certain conclusions regarding the taxation of software royalties in the new Draft Taxation Ruling TR 2024/D1 Income tax: royalties - character of payments in respect of software and intellectual property rights and the implications for the U.S.-Australia tax treaty.
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