The campaign currently being waged by the OECD and its member states against BEPS (Base Erosion and Profit Shifting) is important enough that this issue of this Review is devoted to examining it. Yet over the same period as BEPS has emerged as a matter of worldwide concern, the governments of 17...

The aim of this article is to point to a flaw in one of the measures recently enacted by the New Zealand Government to prevent tax avoidance by large multinational enterprises (MNEs). That measure is section GB 54 of the Income Tax Act 2007, which was added to the Act in July 2018 and which is...

The OECD has for several years been laboriously attempting to reform the international tax system so as to rectify the gross under-taxation of heavily digitalized firms such as Google, Facebook and eBay. Progress has been slow, though, so a number of countries, including New Zealand, have...

The literature on the Hong Kong Basic Law is considerable and a substantial part of it addresses the constraints on the Government’s taxing and spending powers. This article aims to add to it by making two main points. First, whilst the provisions in the Basic Law dealing with the SAR...

Capital gains taxes -- a comparative survey / Michael Littlewood -- The impact of economic theory on capital gains tax reform proposals / David White -- International aspects of capital gains taxation / Craig Elliffe -- Australia / Ann O'Connell -- Canada / David G. Duff -- China / Yan Xu --...

In 2001, the government established the New Zealand Superannuation Fund. This is intended to partially pre-fund the future costs of New Zealand Superannuation, the universal Tier 1 pension payable to all New Zealanders over age 65. The incoming, National-led government suspended contributions in...

When setting public policies on retirement incomes, governments should focus on objectives they have a unique capacity to influence. Only governments can reliably eliminate poverty in old age, level the tax and regulatory playing fields for financial service providers/savers and gather...

The New Zealand tax system was until recently so structured as to allow foreigners to use the country as a tax haven. Specifically, it allowed them to use trusts established in New Zealand (referred to as “foreign trusts”) to avoid and evade the tax they would otherwise have had to pay in...