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.