Australian tax laws have contained a general anti-avoidance rule (GAAR) for over a century. The income tax GAAR proved … it can be shown the dominant purpose of entering into a transaction was to obtain a tax benefit, with eight factors … members. Where the GAAR is applied, the transaction is reconstructed in a way that would have been used if there were no tax …

In this article, the authors examine the Australian government’s newly proposed international tax reform initiatives …

Action 1 and is devoted to withholding tax aspects. This position paper provides possible solutions to the challenges … presented to the international tax regime by the digital economy. The paper considers both the option of installing a … withholding tax mechanism as the primary response to these challenges and the option of using withholding taxes in support of a …