Discussions at the “Freedom of Investment” Roundtables, hosted by the OECD Investment Committee, have stressed that increased investments by foreign State-controlled investors can bring significant benefits to home and host societies, but have also noted that they can raise concerns. This...

Tax planning with intangibles has become one of the most popular and most vividly debated topics in international taxation. We incorporate various intellectual property (IP) tax planning models into forward-looking measures of effective tax rates, namely the disposal of intangibles to low-tax...

Inter-company loans do not draw considerable attention from Multinational Enterprises (MNEs) because they are not core business-related transactions, but planning an interest rate for them is actually important in countries with transfer pricing legislation. Nonetheless, Organisation for...

This paper examines the international corporate tax avoidance practices of publicly listed Australian firms. Based on a hand-collected sample of 203 publicly listed Australian firms over the 2006–2009 period (812 firm-years), our regression results indicate that there are several practices...

As the number of multinational enterprises increases, the number of transactions between entities belonging to the same multinational group rises as well. Intercompany transactions generally offer the opportunity to shift income from one jurisdiction to the other. Income shifting can be driven...

After a period of consultation, it has been decided that the Revenue should be empowered to issue legally-binding rulings in favour of taxpayers only where the relevant transaction has already taken place. This paper considers the reasons for having binding rulings, and argues that those reasons...

The schedular system of income tax in the UK frequently comes under attack, not least in relation to the distinctions it draws between the tax treatment of the employed and the self-employed. However, on examination, it appears that non-schedular systems of taxation share both these distinctions...

Australian taxation law has been criticised for many years for its difficulty to read and understand. The Tax Law Improvement Project (TLIP) was established in December 1993 to rewrite in plain language Australia’s income tax legislation. The primary purpose of this study is to test...