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...

Multinational financial institutions (MNFIs) play a significant role in financing the activities of their clients in developing nations. Consistent with the ‘follow-the-customer' phenomenon which explains financial institution expansion, these entities are increasingly profiting from...

Drafted prior to the adoption of capital gains tax in Australia, this paper sets out the key structural issues to be addressed in the design of a capital gains tax. In each case it considers options and indicates a preferred choice. Topics covered include the type of receipts that should be...

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...

We can pay for our social policy proposals through philanthropy, some kind of user pays arrangement or through taxation. For most of the last century, we have increasingly relied on taxation as the method of financing our expanding welfare state and our growing expectations of citizenship...

This chapter examines the historical development of the formulary apportionment approach in key jurisdictions.From the time income taxes were first widely enacted, tax designers have been concerned with the question of how to allocate profits in transactions that incorporated labour, capital or...

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...