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Australian Tax Forum is a prestigious quarterly journal with the objective of providing discussion on issues in tax policy, law and reform amongst tax professionals.

It is an essential reference source for understanding and contributing to the development of taxation systems worldwide. Australian Tax Forum is aimed at those who want to influence the future development of tax policy. It is an important journal for tax policy makers, academics and libraries.

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Articles from the current issue:

  • The new s 974‑80 – more obscure than ever

    shopping_cart Add to cart 01 Dec 2017

    The classification for Australian tax purposes of financing arrangements involving multiple instruments or disparate parties has been problematic for at least a decade. The recent proposals to revise these provisions will change current law but not obviously improve it. One step in the legislation — the rules about when to aggregate multiple instruments— is detailed, complex and inconsistent. The second step — just how the debt and equity tests are applied where there are multiple instruments
    — and the third step — what the consequences are and for whom, which are meant to follow from aggregation, are ignored. And the decision to create and rely on a new type of legislative instrument makes the endeavour even more uncertain. The article analyses the design of the new provisions and some of the questions which arise from the decision to employ a new type of legislative instrument to elucidate the basic design.

  • The impact of adopting IFRS on corporate ETR and book-tax income gap

    shopping_cart Add to cart 01 Dec 2017

    This study examines the impact of the adoption of the Australian equivalents to International Financial Reporting Standards (AIFRS) on the corporate effective tax rate and book-tax income gap in Australia. Book-tax income gap is measured by the differences between a firm’s effective tax rate (ETR) or current effective tax rate (CETR) and the statutory tax rate (STR). The difference between ETR and STR measures permanent book-tax income gap only, while the difference between CETR and STR measures the total (permanent and temporary) book-tax income gap. This study also examines whether the major accounting rule changes from the previous Australian Generally Accepted Accounting Principles/Practices (AGAAP) to AIFRS, as measured by their respective adjustment to profit before tax and tax expense deflated by the total assets of the firm, affect the changes in ETR and CETR on the adoption of AIFRS in 2005.

  • Evaluating Australian environmental taxes through behavioural economics

    shopping_cart Add to cart 01 Dec 2017

    In the 2016 Climate Action Network Europe review of national climate policies, Australia once again was one of the lowest at 57 out of the 61 countries. Australia’s policies were critiqued for being “unambitious and uninspired”. Numerous studies show that policies are often the key way to address human activity that harmfully warms the climate. Therefore Australia’s unambitious policies require re-evaluation. Furthermore, taxes are a predominant way in which emissions can be reduced. Consequently this paper explores some of Australia’s environment-related tax policies to determine what has best ameliorated humanity’s affect on climate change in Australia.

    The paper carries out its evaluation of Australian environmental taxes by using the Institute of Fiscal Studies’ behavioural economics-based framework (IFS Framework). The IFS Framework represents a formal attempt to integrate behavioural economics into tax policy analysis. Although extensive, in-depth analysis of Australia’s environmental tax policies using traditional economic frameworks exists, there is little analysis using ideas from behavioural economics. Therefore the IFS Framework’s use of behavioural economics presents an opportunity to evaluate Australia’s environmental taxes in a new light.

  • Low oil price shock in Malaysia: Government fiscal impact and petroleum industry reactions

    shopping_cart Add to cart 01 Dec 2017

    The current “shock” of low oil prices as a disruptor to government tax revenue and petroleum industry activity is a concern within the Asia-Pacific region. In the case of Malaysia, the government is heavily dependent on petroleum revenues, which is the reason for this parallel evaluation of government fiscal impact and industry reactions to the slide in world oil prices. The research draws data from publicly available information as well as recent expert interviews. Findings show that low oil prices have impacted the Malaysian Government petroleum-related revenue, resulting in Budget revisions in 2015 and 2016. Malaysia’s new goods and services tax has, however, partly offset lower petroleum revenues. From the petroleum industry perspective, low oil prices are having structural impacts, although reactions have differed to secure cash flows depending on whether an entity is extractive, service or refining orientated. This interdisciplinary research is significant for its up-to-date analysis of changes in government tax policy and the petroleum industry activities. It makes a contribution to understanding government revenue consequences and effects on industry of low oil prices on an ASEAN country that is an export competitor to Australia. It has useful insights for Australia’s 2017 review of petroleum taxation.

  • Tax risk management and the application of ethics by large Australian companies

    shopping_cart Add to cart 01 Dec 2017

    This article reviews tax risk management practices of large Australian companies to ascertain whether ethical considerations are presently, and if not, should be, an element of those practices. An ethical framework, reflecting an agreed ethical philosophy, does not appear to be applied by large Australian companies in setting a standard for consideration and deliberation on acceptable tax risk. This research considers whether a “socially responsible” company would be expected to embed an ethical framework in its tax risk management system, possibly one which would require tax decisions that comply with the “spirit of the tax law” rather than the “letter of the tax law”. It is proposed that a focus on compliance with the “spirit of the tax law” by large companies in making decisions about acceptable tax risk would discourage aggressive tax decision-making and demonstrate a low tax risk appetite.

  • What is the point of having Pt IVA?

    shopping_cart Add to cart 01 Dec 2017

    In much larger, developed economies than Australia, those of the United States of America and the United Kingdom, tax avoidance is or has been addressed not by progressively more intricate general anti-avoidance rules (GAAR) but rather by judicially developed notions of fiscal nullity and fiscal sham. This article considers whether the quest for certainty of application via a GAAR is an illusion and whether, in conjunction with our traditional understanding of sham an adoption of these judicially developed notions and their application as a case by case basis might be just as, if not more effective, then a GAAR in dealing with tax avoidance.

  • The MAAL and DPT: Two roads diverged from the OECD – Did they make any difference?

    shopping_cart Add to cart 01 Dec 2017

    The Multinational Anti-Avoidance Law and the Diverted Profits Tax together constitute a significant step in Australia’s effort to claim a larger slice of the multinational tax pie. This paper undertakes a close reading of each regime, and argues that (i) the DPT may be burdened with some key frailties, particularly in relation to its continued use of a `tax benefit’ concept, and (ii) the regimes do not sit entirely comfortably with Australia’s treaty network.

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