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A new three-tier proposal for determining corporate residence based principally on individual residence

Publication date: 01 Feb 06 | Source: ASIA-PACIFIC TAX BULLETIN

Issue: Vol 11 No 1 Jan/Feb 2005

Pages: pp 14-22

Abstract:
Determining corporate tax residence has become increasingly complicated with the advent of e-commerce.  This article argues that the existing tests are inadequate and that using an individual's tax residence as the basis of determination is the best alternative.

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Author profile

Prof Dale Pinto CTA-Life
Photo of author, Dale PINTO is currently Acting Dean of the Curtin Law School and is a Professor of Taxation Law and Head of the Taxation Department of the Curtin Law School at Curtin University. He is Vice-President of the Divisional Council of CPA Australia (WA Division) and is also a Fellow of CPA Australia, a Fellow of the Australian Academy of Law and is a Chartered Tax Adviser and Life Member of the Tax Institute. Dale is the author/co-author of numerous books, refereed articles and national and international conference papers, and is on the editorial board of a number of peer-reviewed journals as well as being the Editor-in-Chief of several refereed journals. Dale is the Chair of the Tax Institute's National Education Quality Assurance Board and is a member of TEQSA's Expert Panel in Accounting and Taxation. Dale served as an inaugural member of the National Tax Practitioners Board and is a current member of the Board of Taxation's Advisory Panel and the ATO's Tax Technical Panel (Superannuation), as well as the Tax Institute's Technical Committees (Superannuation, Not-for-Profit Organisations and Large Business and International). - Current at 05 February 2016
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