This paper argues that there is too great a reliance placed on anti-avoidance provisions, discretions reposed in the revenue, and judicially developed doctrines as a means of countering tax avoidance. In view of the difficulties in defining and countering tax avoidance, it is suggested that...

The cash economy and associated tax evasion is an on-going issue for most tax administrators. Tax evasion reduces national tax revenue, shifts the tax burden on to other taxpayers such as salary/wage earners and undermines confidence in the tax system affecting voluntary compliance as well as...

Tax avoidance by major US multinationals has been extremely topical over the last decade since the GFC. One of the MNEs at the forefront of this controversy is Google. It has been able to snare a dominant share of the international online advertising market without paying any significant amounts...

The aim of this article is to point to a flaw in one of the measures recently enacted by the New Zealand Government to prevent tax avoidance by large multinational enterprises (MNEs). That measure is section GB 54 of the Income Tax Act 2007, which was added to the Act in July 2018 and which is...

This paper examines the role played by shams in tax avoidance in New Zealand and its relationship with the general anti-avoidance rule (GAAR) encapsulated in statutory provisions. It shows that as long as the orthodox conception of the sham is employed, there is no need for such a mechanism to...

The taxation of high-income earners is of importance to every country and is the subject of a considerable amount of recent academic research. Such high-income earners contribute substantial amounts of tax and generate signifi cant positive spillovers, but are also highly mobile: a 1% increase...

There are two ways for taxpayers to avoid paying taxes: legally, through tax optimization and illegally, through tax evasion. The government reacts by altering the law, and by conducting audits, respectively. These phenomena are modeled as a population game, a strategic interaction between all...

This paper discusses the issue of profit shifting and ‘aggressive’ tax planning by multinational firms. The paper makes two contributions. Firstly, we provide some background information to the debate by giving a brief overview over existing empirical studies on profit shifting and by...

This paper discusses the issue of profit shifting and “aggressive” tax planning by multinational firms. The paper makes two contributions. First, it provides some background information to the debate by giving a brief overview of existing empirical studies on profit shifting and by...

Aggressive tax planning efforts of highly profitable multinational companies (Base Erosion and Profit Shifting (BEPS)) have recently become the subject of intense public debate. As a response, several international initiatives and parties have called for more transparency in financial reporting,...