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...

In an era in which countries seem to be retreating, sometimes at a rapid pace, toward source-based taxation, the importance of a sharp distinction between resident and nonresident companies becomes less obvious. In this context, the proposal by the Australian government in its 2020 budget to...

The evolution of capital gains taxation in Australia parallels that in Canada in many respects. Federal income taxes were adopted in both countries during the First World War, and in both jurisdictions the courts interpreted the term "income," the subject of taxation, using United Kingdom...

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

The statutory test to determine when an individual is a resident of Australia has changed little since it was adopted in 1930, when Australia replaced its territorial-based individual income tax system with a residence-based system. In 2019 the government received comprehensive recommendations...

In this article, the authors look at Australia’s offshore banking tax regime — from its origins to its planned phaseout following criticism from the OECD and EU — and explain why tax incentives and concessions were not sufficient to elevate Australia to a regional financial center

The proprietary nature of corporate management tax policy and corporate tax return information results in very little information being known about the tax aggressive behaviour of these entities. Despite this lack of inside knowledge, tax scholars have continued to attempt to identify corporate...