This paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...

The OECD has for several years been laboriously attempting to reform the international tax system so as to rectify the gross under-taxation of heavily digitalized firms such as Google, Facebook and eBay. Progress has been slow, though, so a number of countries, including New Zealand, have...

This article begins by examining the relationship between thin capitalisation rules and double tax treaties. After examining the potential for a fundamental conflict in this area it looks at the OECD's attempts to resolve the problem (in section 2). In sections 3 and 4, the article examines the...

In 1944, Martin Crowe, a Catholic priest, wrote a doctoral dissertation titled The Moral Obligation of Paying Just Taxes. His dissertation summarized and analyzed 500 years of theological and philosophical debate on this topic, which identified three basic philosophical positions on the issue....