Tax Treaties



New Zealand has traditionally imported capital and relied on foreigners for critical services such as insurance and international shipping, while only exporting primary products in… Read More ›

Naivety, Recalcitrance, and Compromise: A Brief History of New Zealand’s Double Taxation Agreements

All Australian mainland states and territories, except the Northern Territory, levy additional taxes on the ownership of Australian real property by non-citizens who are not… Read More ›

‘Fair(ness) Go(ne)’? Foreigner Surcharge Taxes and Tax Non-Discrimination

Over 130 jurisdictions, representing more than 90 per cent of global GDP, joined the October 2021 Statement on a Two-Pillar solution to address the tax… Read More ›

Three Perspectives on Compliance Challenges of the BEPS Two-Pillar Solution

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

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