This article argues that multinational banks have characteristics which are unique and distinguishable from traditional multinational entities. The first distinguishing feature is the unique nature of the services and consequent products supplied by multinational banks, which are aimed at...

In 2013 the OECD released its 15-point action plan to deal with base erosion and profit shifting (BEPS), which recognised that BEPS has a significant effect on developing countries because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote...

Australian income tax law provides taxpayers making donations to charities with a deduction for the amount of the donations. It also provides public benevolent institutions with an exemption from income taxation for income derived by way of gift or from the investment of donated funds. The...

The issues raised by VAT and financial investments may be the most challenging of all VAT and financial supplies to resolve. In a model VAT, there would be full recovery of all VAT associated with savings and investment. Three problems make it difficult to achieve this aim in respect of...

This paper reviews the income tax model included in the Basic World Tax Code (BWTC) in light of the risk of U.S. tax parochialism by designers. It considers the model in light of specific issues in respect of the measures dealing with income, deductions, the tax unit, company and shareholder...

This paper provides an overview and assessment of alternative methods of taxing capital income. We begin by considering why, and to what extent, capital income should be taxed. Having established a reasonably robust case for such taxation, we then review the difficulties of taxing capital income...

In this article, the authors examine a European Commission ruling that classified the U.K. controlled foreign corporation group financing exemptions as illegal state aid and has now been upheld by the General Court of the European Union. They argue that unlike the commission’s previous state...