Private use of company cars by German employees of Dutch employers - or vice versa, private use of company cars by Dutch employees of German employers - currently results in situations of double and non-taxation, respectively. In this article, I have first concluded that the Netherlands applies...

Place of taxation rules are the seminal cross-jurisdictional provisions of any consumption tax regime. They determine where among competing jurisdictions a particular service is taxed. They are not important for transactions that are restricted to a single jurisdiction and to businesses or...

This paper focuses on the principles underlying the jurisdiction to impose value-added-type consumption taxes (VATs). It analyses existing VAT models to identify the concept of consumption on which they are based and to determine whether there is a common language in which questions of...

The international tax system has always reflected a tension between residence and source taxation from its very beginnings in the 1920s when the first model treaties were devised. After several decades of relative quietude on this front we are currently witnessing a new struggle over...

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...

Does Australia’s international claim to tax trust-level capital gains apply the jurisdictional rules of trust taxation based on source, or those of capital gains taxation based on ‘taxable Australian property’, or a hybrid of the two? The article sets out to answer the question by...

This paper consider the history of the tax treaty rule on royalties up to the emergence of the modern form, the borders of the provision and the fundamental question of why we have it (viewed from an historical perspective). In the modern context of the OECD Model with zero taxation at source on...

The publication of the OECD Model tax treaty in 1977 marked 50 years of development. The Model seeks to remove international tax barriers by reconciliation at the interface of tax systems and has produced a bilateral network because it is generally considered that the diversity of tax systems...

This paper provides a detailed outline of most of the major features of the Australian goods and services tax (GST). As well as explaining and evaluating the operation of the GST law, the paper compares the Australian GST with the equivalent features of the European VAT. The paper was first...

Graham Hill was for many years the pre-eminent tax judge in the Federal Court of Australia. Throughout his career as a tax practitioner, and then as a judge, he taught stamp duties, sales tax, and later goods and services tax (GST/VAT), in the Masters of Law program at Sydney Law School. His...