Australian tax laws have contained a general anti-avoidance rule (GAAR) for over a century. The income tax GAAR proved robust for over half a century but ceased to be effective when read down in the 1970s and was replaced in 1981. The current GAAR has been recently amended to include specific...

Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational...