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Royalties in the Spotlight: The Significance of the Oracle Decision in Australian Tax Law

A. Stamoulos

International Transfer Pricing Journal2025https://doi.org/10.59403/gtya40article
ABDC C
Weight
0.46

What the paper says

In Oracle Corporation Australia Pty Ltd v. Commissioner of Taxation (Stay Application) [2024] FCA 1262, the Federal Court denied an application by Oracle Group for a temporary stay of domestic tax proceedings pending the conclusion of a MAP pursuant to the double taxation treaty between Ireland and Australia. It was held by Perram J that the submissions in favour of granting a stay of domestic proceedings were outweighed by the need for a final appellate determination on what constitutes a “royalty” under Australia’s numerous double taxation agreements.

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https://doi.org/https://doi.org/10.59403/gtya40

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@article{a.2025,
  title        = {{Royalties in the Spotlight: The Significance of the Oracle Decision in Australian Tax Law}},
  author       = {A. Stamoulos},
  journal      = {International Transfer Pricing Journal},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.59403/gtya40},
}

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Royalties in the Spotlight: The Significance of the Oracle Decision in Australian Tax Law

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Evidence weight

0.46

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.37 × 0.4 = 0.15
M · momentum0.60 × 0.15 = 0.09
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.