R eview Software Arrangements for 'royalty' payments The recently released ATO draft taxation ruling TR 2024/D1 has significant impact on taxpayers once finalised. If you have a software arrangement with an overseas provider, and:   1.    distribute or resell software in Australia 2.    pay a subscription fee for a software as a service ( SaaS ) solution 3.    are granted or have a right to use intellectual property ( IP ) 4.    sell hardware with embedded software   then rev