This paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...

This article discusses the current state of tax treaty interpretation in New Zealand with particular reference to a recent decision which has attracted attention both here in New Zealand and overseas. The case concerned whether a New Zealand resident was entitled to a tax sparing credit under...

Assessing BEPSThe government has reviewed New Zealand's current policy settings and determined that most are robust and fit for purpose. Having identified hybrid mismatch arrangements, interest allocation and transfer pricing as issues that may need addressing, it is developing and refining its...

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...

In this paper it is controversially suggested that international tax law is broader than the traditional view of most academics. In addition to domestic laws that cover cross-border transactions and double taxation agreements (or their multilateral counterparts) there is a special consensus...

"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...