The case law in Australia on the interpretation of the definition of royalties under tax treaties is not in a very satisfactory state. In particular in a sample of four judgments in recent years the decisions with one exception seem to avoid coming to grips with the OECD Commentary on royalties...

The RCF case raises a number of issues in relation to the principles in the OECD Partnership Report on the application of tax treaties to hybrid entities. The judgments do not finally settle the status of those principles in Australia but they point more to approval of the principles than...

This article considers the recent final (non) report of the Australian Business Tax Working Group which was set up to review how to finance a cut to the corporate income tax rate and/or whether Australia should adopt an allowance for corporate equity or other structural reform to the corporate...