Globalization and the increasing trend in reduction of trade barriers have propelled businesses to capture growing levels of activity across borders. The range of such activities has been equally dispersed between the pursuit of new markets for products and services, and in the quest for more...

New Zealand has concluded double tax agreements with 24 countries. Double tax conventions are brought into effect by Orders in Council, a form of subordinate legislation. They are also incorporated in legislation by reference under section 294 of the New Zealand Income Tax Act 1976, which states...

A report on a conference organised jointly by the Institute of Policy Studies, Wellington, the Asian Pacific Tax and Investment Centre, Singapore, and the Australian Tax Research Foundation, Sydney. The purpose was to study judicial and legislative anti-avoidance measures and treaty policies in...

In this article, the author explores and advocates the use of an artificial intelligence tax treaty assistant with regard to resolving issues and problems in respect of the principal purpose test as proposed in relation to the OECD/G20 Base Erosion and Profit Shifting initiative. As the PPT is...

The Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is one action by the OECD to address tax-base erosion and profit shifting (BEPS), i.e., double non-taxation or strategies consisting of artificially shifting profits to low-tax...

The benefits of a tax treaty are generally granted to persons who are residents of one of the Contracting States. The determination of such tax residence status is, however, not always an easy task and is particularly problematic in relation to entities whose tax characterisation differs from...

This article discusses the current state of tax treaty interpretation in New Zealand with particular reference to a recent decision which has attracted attention both here in New Zealand and overseas. The case concerned whether a New Zealand resident was entitled to a tax sparing credit under...

Discourse on the merits and pitfalls of multilateral cooperation for advancing justice in international tax law have recently re-emerged in the literature. Some tax scholars, even while criticizing global projects like the OECD/G20 initiatives on base erosion, profit shifting and the tax...

This case note analyzes the outcome of the Spanish Colgate-Palmolive case, decided by the Supreme Court in September 2020. The case revolved around the interpretation of Article 12 of the Spain-Switzerland tax treaty (1967), on royalties, which omits any reference to the beneficial owner of the...