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...

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

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...

Business tax reform in Australia. Includes analysis by local and overseas industry experts of past tax reforms, our current business tax system and potential future developments as canvassed by the Australian Government's Future Tax System Review (Henry Review)

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...