Virgin Holding SA v. Commissioner of Taxation was a decision in the Federal Court of Australia in late 2008. It concerned a very important issue in the interpretation of the Australia-Swiss double taxation conventions. This was whether the term "income tax" included tax on capital gains. The...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...

Does Australia’s international claim to tax trust-level capital gains apply the jurisdictional rules of trust taxation based on source, or those of capital gains taxation based on ‘taxable Australian property’, or a hybrid of the two? The article sets out to answer the question by...