Tax Treaties



More than five years have passed since the implementation of the Base Erosion and Profit Shifting (BEPS) package through the Inclusive Framework. Tax certainty remains… Read More ›

Does the OECD’s Peer Review Process Ensure Certainty for Tax Treaty Dispute Resolution Mechanisms?

Since 2018, the Organisation for Economic Co-operation and Development (OECD) has tried to find a way to tax digital companies that is agreeable to most… Read More ›

In Search of a Solution to Tax the Digital Economy

The acceleration of the globalisation of Australia’s economy and increasing use of digital technology in business and trade has put pressure on governments to efficiently… Read More ›

Deemed Source of Income: Expanding Australia’s Domestic Tax Base

To what extent do taxes influence foreign direct investment (FDI) in developing countries? In most of the developing world, tax incentives are employed to attract… Read More ›

Tax Incentives and Foreign Direct Investment in Developing Countries

For all of international tax’s history, the decision of which country should tax cross-border income has rested upon two fundamental legal concepts: ‘residence’, a tax… Read More ›

The International Seabed Authority and the Future of Tax

Australian tax treaties are undergoing the most extensive revision in their history as ratifications under the Multilateral Convention to Implement Tax Treaty Related Measures to… Read More ›

Australian Tax Treaties and Transparent Entities After the Flood

Attracting inbound foreign direct investment (FDI) by multinational corporations has long been an important objective of many governments in developing and transition economies. In view… Read More ›

Tax Sparing Agreements and Foreign Direct Investment in Developing Countries

The latest 2017 Organisation for Economic Co-operation and Development (OECD) statistics on the resolution of tax treaty disputes, through the unique tax treaty resolution mechanism… Read More ›

The Optimal Way to Resolve Tax Treaty Disputes: Litigation or Arbitration?

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