Selected aspects of Australia's emerging "model" double taxation treaty.
01 Feb 08 |
BULLETIN FOR INTERNATIONAL TAXATION
Issue: Vol 62 No 2 2008
This article examines selected aspects of Australia's emerging "model" tax treaty which reflects the changes in its tax treaty policy. The article first summarises the findings and recommendations of the Review of Business Taxation and the Review of International Taxation Agreements in respect of Australia's treaty policy. The article then discusses the changes in Australia's tax treaty policy, which include (a) moving towards a more residence-based treaty policy, (b) giving priority to (re)negotiating treaties with Australia's major trading partners, (c) modernising Australia's treaty policy - pertaining to eg exchange of information, assistance in collection and non-discrimination, and (d) improving the consulation processes on negotiating treaties. The article concludes that, going forward, Australia's "model" treaty will more closely resemble the OECD Model as, in economic terms, Australia moves from being a capital importer to being a capital exporter.
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Michael is Professor of Taxation Law at the University of Sydney. He has a PhD on Australian international taxation and is a noted researcher, having authored Is it Australia's? Residency and Source Analysed (2005, Australian Tax Research Foundation), as well as authoring and co-authoring over 590 publications and papers. From May 1999 until October 2009 he was, as Senior Tax Counsel for the Taxation Institute, in the forefront of the all major tax reform and taxation administration reforms. He continues his involvement as a member of the Treasury's Tax Treaties Advisory Panel and the Education Committee of the Tax Practitioners Board. He was awarded the Australasian Tax Teachers Association's Graham Hill medal in recognition of his "outstanding contribution to the teaching of taxation law and policy" on 21 January 2010.
- Current at
29 October 2012