eCite Digital Repository

Australian International Income Taxation: Policy, Principles and Practice

Citation

Taylor, J and McLaren, JA and Dirkis, M and Jogarajan, S and Walpole, M, Australian International Income Taxation: Policy, Principles and Practice, Thomson Reuters, Australia, Australia ISBN 9780455242699 (2021) [Authored Research Book]

Copyright Statement

Copyright 2021 Thomson Reuters

Abstract

The Global Financial Crisis of 2008 left many economies with significant budgetary problems. In the search for revenue, the Organisation for Economic Cooperation and Development (OECD) and the Group of 20 Nations (G20) in 2012 charged the OECD with the ‘Base Erosion and Profit Shifting’ (BEPS) project, examining international tax planning by multinational groups. BEPS has been a major theme in international tax discussion since with the project being opened to non-OECD countries through its ‘inclusive framework’. Progress was rapid with the OECD producing an initial report and an Action Plan in 2013. Subsequently, several reports in OECD countries and in the European Union dealt with issues related to BEPS culminating in the publication of the Final BEPS Reports, the Multilateral Instrument and the 2017 update to the OECD Model Tax Convention.

The BEPS project, however, did not end there and remains a work in progress. The focus is now on what has become known as Pillar I and Pillar II which are concerned with tax issues arising from the digitisation of the economy and raise fundamental jurisdictional questions about the relative taxing rights of residence and source countries.

Although one of the insights of the BEPS project has been recognition of the need for co-ordinated responses by countries to cross-border tax planning strategies many of the recommendations in the BEPS Final Reports can only be implemented by national legislation. Hence, the need for this publication on Australian international income tax law that analyses the current domestic law and tax treaty provisions and takes into account the recommendations in the BEPS Final Reports.

After discussing international tax policy considerations and the historical development of current Australian rules in the introduction, three chapters examine Australian domestic law rules that apply in the absence of a double tax treaty. Australian double tax treaties and their effect on domestic law are then analysed in Chapter 5. The final two chapters discuss Australian international anti-avoidance provisions and administrative aspects of Australian international taxation. This book provides a thorough discussion of current Australian international tax rules and their implications for taxpayers.

Item Details

Item Type:Authored Research Book
Keywords:international taxation, tax treaties, multi-national tax avoidance
Research Division:Law and Legal Studies
Research Group:International and comparative law
Research Field:Comparative law
Objective Division:Law, Politics and Community Services
Objective Group:Justice and the law
Objective Field:Legislation, civil and criminal codes
UTAS Author:McLaren, JA (Dr John McLaren)
ID Code:145004
Year Published:2021
Deposited By:TSBE
Deposited On:2021-06-24
Last Modified:2021-07-01
Downloads:0

Repository Staff Only: item control page