In an era in which countries seem to be retreating, sometimes at a rapid pace, toward source-based taxation, the importance of a sharp distinction between resident and nonresident companies becomes less obvious. In this context, the proposal by the Australian government in its 2020 budget to...

World events in the first decade of this century led many to question the state of the international tax regime and the role it could play in solving national fiscal problems. In 2012, leaders of the Group of 20 (G20) set the OECD an ambitious agenda of working out how tax base erosion and...

In this article, the authors look at Australia’s offshore banking tax regime — from its origins to its planned phaseout following criticism from the OECD and EU — and explain why tax incentives and concessions were not sufficient to elevate Australia to a regional financial center

The proprietary nature of corporate management tax policy and corporate tax return information results in very little information being known about the tax aggressive behaviour of these entities. Despite this lack of inside knowledge, tax scholars have continued to attempt to identify corporate...

In this article, the authors explain the compromise approach developed by courts when setting transfer prices for transactions where there are no actual comparable arm’s length prices and illustrate the process with recent examples from Australia

The statutory test to determine when an individual is a resident of Australia has changed little since it was adopted in 1930, when Australia replaced its territorial-based individual income tax system with a residence-based system. In 2019 the government received comprehensive recommendations...

Formulary apportionment does not attempt to undertake a transactional division of a highly integrated multinational entity. Rather, it allocates income to the jurisdictions based on an economically justifiable formula. Opposition to formulary apportionment is generally based on the argument that...

In response to developments in international trade and an increased focus on international transfer-pricing issues, Canada’s minister of finance announced in the 1997 budget that the Department of Finance would undertake a review of the transfer-pricing provisions in the Income Tax Act. On...

The limited impact made by foreign banks in the Australian retail banking sector has been described as "one of the disappointments" of the deregulation of the Australian financial system. Changes have since taken place. This article examines the current position of foreign bank branches in...