If:
(a) a company incurs expenditure for the provision of what is essentially a service; and
(b) the results of the service are provided to the company by being embodied in goods that are delivered to the company; and
(c) the service that is embodied in the goods was predominantly performed outside Australia;
the service is not provided to the company in Australia merely because the goods are delivered to the company in Australia.
Note: Paragraph (b)--a document, for example, might set out legal or other professional advice or a computer disk might contain a program that has been made or data that has been compiled.