This paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...

This is a chapter of a book on foreign investment fund regimes. Most features of foreign investment fund regimes fit reasonably neatly into the analytical framework of definition, boundaries, scope, exceptions, and calculation of income, topics that are dealt with in other chapters of the book....

The expression “foreign” or “overseas investment fund regime” can be misleading. The direct targets of such a regime are local residents of the country that enacts the regime. Overseas investment fund regimes aim only indirectly at investment funds in other countries. The objective of a...

Ordinarily, double tax conventions restrict their benefits to residents of the states that are parties. Moreover where a resident of one state claims relief in respect of income derived from the other state, the claimant must ordinarily be “beneficially” entitled to the income in question....

A report on the International Tax Workshop of the University of New South Wales Taxation, Business, and Investment Law Centre held in August 1988. An important topic of the conference was the proposed Australian controlled foreign company and foreign trust legislation

This paper discusses foreign shipowners who transport cargo between domestic ports, using ships that are engaged primarily in the international import/export trade. It compares the taxation of such foreign shipowners with the taxation of coastal shipowners. Areas of comparison include business...

This paper sets out the text and translations of over sixty of the world's general anti-avoidance rules. General anti-avoidance rules are found in taxation statutes. Known as “GAARs”, they are perhaps the most intractable of all statutory provisions, challenging alike to policy-makers,...