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  • Australia Finalises Software Royalty Ruling and Introduces New ATO Risk Framework

    The Australian Taxation Office has finalised its position on the treatment of cross-border software payments, issuing Taxation Ruling TR 2026/2 alongside a revised draft compliance framework, PCG 2026/D4. The developments are particularly relevant for multinational technology groups using Australian distributors, resellers or other intermediaries to provide software and cloud-based products to Australian customers. The central question…