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Cataloguing international tax reform 12 years on


Twelve years have elapsed since the Review of Business Taxation (RBT) set out its international business tax reform recommendations in A Tax System Redesigned and 10 years have now elapsed since the Review of International Taxation Arrangements (RITA) was announced. These reviews were the first major evaluation of Australia’s international tax regime since the late 1980’s and early 1990’s when Australia’s international tax rules were ‘modernised’.

As tax reform is not a linear process, many recommendations have been implemented or shelved, while others have continued to evolve (eg Australia’s tax treaty policy) or have been absorbed into other projects (eg Board of Taxation, Review of the Foreign Source Income Anti-deferral Regimes: Report (September 2008)). Other international tax reform measures were progressed outside the RBT and RITA processes. Given the magnitude of the changes it has been difficult to track:

  • what were the outcomes of the reviews
  • which recommendations were adopted
  • which recommendations have been enacted and
  • which measures are still outstanding or have lapsed.

As the Government commences to implement the recommendations of Australia’s future tax system: Report to the Treasurer, released on 2 May 2010, it is crucial to catalogue the reform outcomes, particularly as the Report did not focus on international tax issues. This is done by first providing a brief overview of the key international reform processes before providing detailed history of the reform proposals and their fate in tabular form.

Author profiles

Prof Michael Dirkis CTA
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
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Brett Bondfield CTA
Brett is a Lecturer in the Business Law, Faculty of Economics and Business, University of Sydney. - Current at 01 July 2011
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