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Taxation of software transactions

The coronavirus disease 2019 (Covid-19) pandemic led people to significantly limit physical interactions; thus, it accelerated and strengthened the expansion of digital transactions. People now prefer transmission or delivery of documents, goods, and all other items, electronically, if possible. This also speaks true for software transactions where the software may be transferred electronically, instead of delivery through variety of media, such as magnetic tape, disk, CD-ROM, and the like.

Software is defined as 'a program, or a series of programs, containing instructions for a computer required either for the operational processes of the computer itself (operational software) or for the accomplishment of other tasks (application software).' (Section 2, Revenue Memorandum Circular [RMC] 44-2005, Sept. 1, 2005). It is 'generally assimilated to literary, artistic or scientific work protected by copyright laws.'