This is an interesting (but wrong) decision covering a variety of issues:
whether embedded IP should be separated out of a product price for royalty withholding tax purposes, even if the independent parties determined the sale to be royalty free;
whether a sale of a product from Australia to Singapore (via Australia) can invoke the AUUS tax treaty;
whether diverted profits tax is the better alternative for the above;
a judge's lack of understanding of how business works undermines the quality of his decision; and
an in depth look at more than 4 different ways, proposed by 2 different expert witnesses, of calculating the royalty amount for the above embedded IP.

This first video deals with the embedded IP issue.

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Decision
https://www.judgments.fedcourt.gov.au...

Judge Moshinsky background
https://www.fedcourt.gov.au/about/jud...