World events in the first decade of this century led many to question the state of the international tax regime and the role it could play in solving national fiscal problems. In 2012, leaders of the Group of 20 (G20) set the OECD an ambitious agenda of working out how tax base erosion and...

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...

Widely publicised profit-shifting cases in Europe against multinationals such as Starbucks, Fiat, Apple and Amazon have caught the attention of Australian scholars and tax officials with the revelation of the direct involvement of Australian subsidiaries such as Apple in the arrangements. The...

China attracted considerable foreign investment following the opening of its economy in 1979. With the switch to a quasi-market economy, China became reliant on taxes to fund government, opening the door to potential double taxation of profits from foreign investment, first in China and second...

The SNF case in Australia revealed that in Australia a court could interpret domestic transfer pricing rules differently from those in Australia's tax treaties. In particular, the court rejected the use of OECD transfer pricing guidelines to determine an arm's length price under domestic law....

In this article, the authors explain the compromise approach developed by courts when setting transfer prices for transactions where there are no actual comparable arm’s length prices and illustrate the process with recent examples from Australia