This paper reviews the income tax model included in the Basic World Tax Code (BWTC) in light of the risk of U.S. tax parochialism by designers. It considers the model in light of specific issues in respect of the measures dealing with income, deductions, the tax unit, company and shareholder...

This paper looks at the sources for VAT design in Africa. It begins with a brief comparison of the two alternative designs used for taxes on final consumption, the retail sales tax and the value added tax. While the VAT has emerged as the consumption tax of choice outside North America, both...

Looking back on the evolution of taxation reform in developed economies over the post-war period, we observe that the early decades were marked by a determined effort to implement reforms based on Haig-Simons principles of a comprehensive income taxation. Under this approach all the various...

No metaphor is dearer to the hearts of Australian tax scholars and practitioners than the fruit and tree depiction of income and capital. An important characterisation in early economic theory, the agricultural allegory was imported into Australian income tax law not long after the adoption of...

‘Simplification' has been the mantra of tax reformers and tax deformers since the late 1950s and has frequently been cited as a rationale for tax changes in the closing years of the twentieth century and the opening years of the twenty-first. The near universal agreement by tax critics that...

The scope of the Northern Territory stamp duty was tested on September 30 in an appeal to Australia's High Court, the final court of appeal, in a case (Alcan (NT) Alumina Pty Ltd. v. Commissioner of Territory Revenue, [2009] HCA 41) involving Alcan, the multinational aluminum manufacturer and...

While the calculation of taxable income under Australian income tax law is similar to the calculation of net profits under accounting standards, there are some fundamental differences between the two systems. These derive in part from the structure of the legislation, in part from the...

Civil law scholars often assume there are general differences in the approaches taken to the interpretation of income tax laws in civil law jurisdictions and common law jurisdictions. However, these differences may be dwarfed by the different approaches taken by two camps within the common law...

After many decades of actual and proposed reform, Australia's rules for the taxation of debt arrangements remain deeply flawed. A notable problem is the absence of appropriate rules for dissected debt arrangements, where a creditor dissects a debt into interest and principal repayment components...

The income tax and GST laws contain an array of rules that apply to debt and gains in the nature of interest. The definitions of “debt” or “loan” and amounts in the nature of “interest” vary across the provisions and tax officials, taxpayers and courts must decide whether the terms...