Destiny has entered into a contract with an advertising agency to appear in a series of television commercials promoting shampoo made by The Spiky Hair Ltd. Destiny has become identified with a character in a local television series, and the commercials will be based on that series. She is a self-employed actor. She receives $100,000, which is paid in a lump sum upon Destiny signing the contract (on 1 April 2019). From the $100,000, $40,000 is specified for acting services and the remaining $60,000 is made in return for Destiny agreeing for a period of two years not to be associated with the promotion of any other products that are in competition with the shampoo of The Spiky Hair Ltd. Destiny seeks your advice on the treatment of the $100,000 payment.

Explain with references to the ITA 2007, the tax consequences of the receipt of $40,000 for acting services and $60,000 for a restrictive covenant in the hands of Destiny