In considering how tax administrators should relate to tax intermediaries, one approach has been to move tax administrators from a command and control posture to a more sophisticated form of regulation, as recently endorsed by the OECD's "enhanced relationship" model. For the last decade,...

Drawing upon the theory of responsive regulation, in the 1990's the Australian Commissioner of Taxation expressed the partnership model of tax administration. Shortly afterwards, the New Zealand Inland Revenue Commissioner joined this shift, to what has been caste as, the way forward in meeting...

In 1998, the OECD issued a report announcing an initiative to eradicate harmful tax practices world wide. Non-OECD states with preferential tax regimes were labelled tax havens and the focus of the report soon became these countries.The tax havens' primary response has been to point to the...

Countries around the globe are currently struggling with the seemingly conflicting goals of maintaining the integrity of their company/shareholder tax regime whilst not presenting a disincentive to both inward and outward investment. In this regard, the standard adopted by most developed...

The failure by Parliament to define the meaning of income in our income tax laws left the task to the judiciary. Traditionally legalistic trust law distinctions between income and capital have prevailed, requiring an analysis in terms of the source of the flow of the benefit.Proponents of an...

Following the full Federal Court decision in Montgomery v FC of T 98 ATC 4120 a basis on which to reconcile the lease incentive cases was discernible. Namely where there was obligation to spend the incentive payment on capital expenditure that did not increase the value of the taxpayer's...

During the last decade the judiciary and policy makers in both Canada and Australia have struggled to define coherent principles pertaining to the deductibility of interest on borrowed funds. Neither jurisdiction has appeared to make reference to the experiences in the other notwithstanding that...

The Japanese income tax system was redesigned following World War II. As such it has features of the systems of both Europe and the United States, although in many respects it is quite unique. Whilst it arguably contributed to Japan's meteoric rise to the status of an economic superpower, little...