The RCF case raises a number of issues in relation to the principles in the OECD Partnership Report on the application of tax treaties to hybrid entities. The judgments do not finally settle the status of those principles in Australia but they point more to approval of the principles than...

2008 was a significant year for scholars interested in the history of tax treaties. Apart from the Rust tax treaties history conference, the main event was the release of the OECD archives in September when the OECD celebrated the 50th anniversary of the OECD Model (or more accurately the...

The current rules in tax treaties for business profits of permanent establishments (PEs) have recently received their greatest alteration since they were created in the 1950s as a result of the Report on Attribution of Profits to Permanent Establishments representing over a decade of work by the...

This article considers the recent final (non) report of the Australian Business Tax Working Group which was set up to review how to finance a cut to the corporate income tax rate and/or whether Australia should adopt an allowance for corporate equity or other structural reform to the corporate...

The OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) is receiving significant attention from taxpayers and national governments. Because the action plan is about action, it contains little discussion of the tax policy questions involved. One of the less-noticed aspects of the plan...

This material was first published by Sweet & Maxwell Limited in Angelo Nikolakakis, Stephane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Johann Hattingh, Koichi Inoue, Juergen Luedicke, Guglielmo Maisto, Toshio Miyatake, Kees van Raad, Richard Vann and...