This paper reports on a study of the tax treaty policy of a group of eleven East African countries. African tax treaties tend to follow one of two model treaties, an OECD model treaty that favours the interests of capital exporting nations and a United Nations model treaty that allows capital...

Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...

This paper looks at the sources for VAT design in Africa. It begins with a brief comparison of the two alternative designs used for taxes on final consumption, the retail sales tax and the value added tax. While the VAT has emerged as the consumption tax of choice outside North America, both...

While the calculation of taxable income under Australian income tax law is similar to the calculation of net profits under accounting standards, there are some fundamental differences between the two systems. These derive in part from the structure of the legislation, in part from the...

Civil law scholars often assume there are general differences in the approaches taken to the interpretation of income tax laws in civil law jurisdictions and common law jurisdictions. However, these differences may be dwarfed by the different approaches taken by two camps within the common law...