n Without Prejudice - The IBM case : tax international law
|Article Title||The IBM case : tax international law|
|© Publisher:||JetBlue Publishers (Pty) Ltd|
|Affiliations||1 Cliffe Dekker Hofmeyr|
|Publication Date||Jul 2011|
|Pages||39 - 40|
The Federal Court of Australia on April 12 2011 gave a far-reaching judgement in the case of International Business Machines Corporation (IBM) v COT dealing with whether all payments made by IBM to its US holding company constituted royalties for purposes of the Treaty concluded between Australia and the USA.
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