The Australian and Japanese Governments have both introduced a tax consolidation regime effective fiscal year 2002103. The two regimes have many similarities. In particular, they both mandate 100 per cent ownership as the threshold for consolidation, consolidation is voluntary but if elected all...

In both his 2013 and 2014 annual reports the Australian Inspector-General of Taxation wrote of the need to consider the adoption of a taxpayers' bill of rights in Australia. Whilst a charter of taxpayer rights has been a feature of ATO administration for almost two decades it does not provide a...

The “technological revolution” is influencing almost all aspects of our lives. Certainly the law has not been immune from its influence. Legal practice in Australia is currently undergoing a major disruption. Tax law has been at the vanguard of this phenomenon. The massive amount of...

Since World War II the Japanese economy has been spectacularly successful. The sources of this success have been the subject of considerable debate. The Government's use of taxation policy in assisting favoured industries has been identified. Whilst there are mixed views as to the significance...

In contrast to countries such as Malaysia, Singapore and the United Kingdom, Australia has reacted belatedly to the phenomenon that is Islamic Finance. Nevertheless, there is no evidence that the delay is the result of a deeper consideration of the issues. The terms of reference provided to the...

The approach to administration of the Australian tax system has, over time, fluctuated between an adversarial and a co-operative approach. Currently, consistent with a move to a responsive regulatory strategy, the Australian Tax Office (“ATO”) has expressed its desire for a co-operative...

The hierarchy of the Australian Tax Office (“ATO”) presents a picture of the ATO being in a partnership with the tax profession. It is suggested that the relationship is, or should be, one of co-operation with the aim to maximize voluntary compliance with the tax system by taxpayers.Such a...

The rule of law imperative, so often espoused by industrialised nations, is under siege as tax systems attempt to interface with an ever increasingly complex and globally focused business environment. Compliance by taxpayers and enforcement by the tax administrator has become progressively...

The Australian and Japanese Governments have both introduced a tax consolidation regime effective fiscal year 2002/03. The two regimes have many similarities. In particular, they both mandate 100 per cent ownership as the threshold for consolidation, consolidation is voluntary but if elected all...