This article examines two broad areas of capital gains tax (CGT) design in respect of the taxation of non-residents. The first area relates to the domestic design of the tax and focuses on whether a CGT should apply to all assets held by non-residents or to some limited subset of those assets...

Cover -- Half-title -- Series information -- Title page -- Copyright information -- Dedication -- Contents -- List of Figures -- Preface -- Background to This Book -- Structure of the Book -- Acknowledgements -- Part I -- 1 Taxing Cross-Border Business Income -- 1.1 What Is Cross-Border...

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...

"In 2018, the total global e-commerce market worth roughly USD 7.7 trillion. Despite the size of this economy and its extraordinary growth rate, many multinational companies paid little tax in the countries in which they did business. This is not a problem that can be ignored. Digital companies...