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The theoretical foundations and continued rationale for source-based taxation in an electronic commerce environment


This paper is directed at analysing the theoretical foundations and rationale for source-based taxation and argues that these principles remain valid despite changes brought about by globalisation, including the increased incidence of transactions that occur via electronic commerce.

The analysis in this paper is not concerned with how source is defined, but rather at establishing that source-based taxation continues to be theoretically justifiable for income that arises from international transactions which are conducted in a globalised business environment, including those that occur through the agency of electronic commerce.

Author profile

Prof Dale Pinto CTA-Life
Photo of author, Dale PINTO Dale Pinto is currently a Professor of Taxation Law in the Curtin Law School at Curtin University. He is the 2018 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 Accountant, 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 16 February 2018
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