The Nuts and Bolts of Value Shifting

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Published on 01 Apr 03 by "THE TAX SPECIALIST" JOURNAL ARTICLE

This article examines the operation and impact of the new highly complex GSVR, identifying the practical implications.

Author profile

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 15 February 2016

More by Dr Michael DIRKIS

Curious cases of footballers, aircraft crew, lawyers, scientists and a motel - The general deduction jurisprudence of Justice Graham Hill - 01-June-2013
The residence of companies and trusts revisited paper - 17-October-2012
Cataloguing international tax reform 12 years on - 01-February-2012
Ahead of “two days in October”: Reviewing the status of the recommendations of Australia’s future tax system review - 01-September-2011
Getting your practice ready for the new Tax Agent regulatory scheme paper - 17-November-2009
"The science of tax design?”: Tax policy within the Australian Government’s White Paper on the Carbon Pollution Reduction Scheme (CPRS) - 01-November-2009
Taxing beyond Australia’s horizon: the section 23AG changes - 01-September-2009
Revealing Australia’s carbon pollution reduction scheme - 01-August-2009
Déjà vu: The tax aspects of the CPRS White Paper - 01-February-2009
Cover: Still searching for certainty: the tax aspects of the Carbon Pollution Reduction Scheme - 01-November-2008
CPRs for the environment or the tax system? Exploring the tax aspects of the Green Paper - 01-August-2008
Keeping ahead in the developments of climate change - 01-June-2008
Selected aspects of Australia's emerging "model" double taxation treaty. - 01-February-2008
Engaging with our region: AOTCA and SGATAR - 01-February-2008
Senior Tax Counsel: Update on the tax consultative agenda - 01-August-2007
Ripe for reform: Australia's domestic source rules - 01-April-2007
Selected aspects of source and residency in the new millennium paper - 16-March-2007
Cataloguing Business Tax Reform Seven Years On - 01-September-2006
At The Extremes of a Good Tax Policy Process - 20-July-2006
Relationship matters – Leading the Australian Tax Office - 01-May-2006
Senior Tax Counsel's Report: More than initials - FBT, FTB, TOFA, JCPAA, and other tax developments - 01-April-2006
Editorial Message: Pinning down elusive simplicity - 01-February-2006
The same old same old: Corporate residency after RITA - 01-January-2006
Senior Tax Counsel's Report - 01-November-2005
At the extremes of a - 16-August-2005
Tax Counsel's Report - 01-August-2005
Dealing with government, Treasury and the ATO - a three ringed circus? paper - 19-May-2005
Senior Tax Counsel's report - 01-May-2005
Senior Tax Counsel's Report - 01-April-2005
Tax Director's Report - 01-October-2004
Tax Director's Report - 01-August-2004
Standing on the outside [not] looking in: International taxation reform outside RITA - 01-June-2004
Tax Director's Report - 01-June-2004
The RBT ANTS Bite: Small Business the First Casualty - 01-April-2004
Overview of Australian Tax Reform - 27-February-2004
Fixing your tax problem: where to go for what and why? seminar paper - 29-March-2003
Value Shifting seminar paper - 28-February-2003
Review of developments - 12-December-2002
Reviewing the "Review of International Taxation Arrangements" - 14-October-2002
Reviewing an international tax review - 01-October-2002
Observations on the Development of Australia's Income Tax Policy and Income Tax Law - 01-October-2002
Evaluating the new general value shifting regime - 29-August-2002
Self Assessment: Time for a Change - 01-March-2002
Where we were; Where we are; Where we want to be: a review of Australia's residency rules. - 01-October-2001
Simplified Tax System - 18-May-2001
The BAS Changes: They promised it would be easy - 01-March-2001
The BAS Changes: A failure in consultation or a failure to listen? - 01-March-2001
Selected Aspects of the Proposed Entity Tax - 17-February-2001
Taxation Reform for Small Business - 20-October-2000
The Ralph Report: a step closer, a step farther away - 01-November-1999
A step closer, a step farther away - 01-October-1999
Administrative reform proposed for the ATO - 01-September-1999
Administrative policy: why the ATO needs formal advisory boards - 01-September-1999
I ATO, therefore I am: a question of existence, boards and statements of principle - 01-August-1999
Taxation ruling TR 1999/5: the dangers of retrospectivity - 01-June-1999
The 1997 Tax Act: old chassis, new shell - 01-August-1997
Australia: tinkering at the edges: recent changes to the foreign source income regime - 01-July-1997
Accidents of history - Australia's residency rules for individuals - 01-June-1997
Recent developments: child maintenance trusts| recent changes to the taxation of minors - 06-November-1996
The income tax simplification experience to date - 01-February-1996
Foreign income: a FIF tale. Part 1: a practitioner's guide to the taxation of foreign investment funds - 01-October-1993
Foreign income: a FIF tale. Part 2: the sting in a FIF tale - 01-October-1993
Foreign income: a FIF tale. Summary - 01-October-1993
Left in limbo: - 01-June-1993
Foreign income: out of sight - not out of mind - 01-August-1992
Foreign income: out of sight - not out of mind. Summary - 01-July-1992
Tax traps in the financial structures of 'resident funded' retirement villages - 01-September-1991

Click here to expand/collapse more articles by Dr Michael DIRKIS.

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