Review of the “source of income” rules

This paper looks at key issues including:
  • significance and meaning of “source”
  • source principles relating to certain types of income
  • relevance of DTAs and MLI
  • Commissioner of Taxation v RCF IV LP [2019] FCAFC 51 (“RCF IV”)
  • treaty source rule and Satyam Computer Services Limited v Commissioner of Taxation [2018] FCAFC 172 (“Satyam”).

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