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Designed for the specialist tax professional, The Tax Specialist journal is essential reading for corporate tax advisers, accountants, lawyers and academics. Featuring in-depth analysis, opinion and argument on legislative, administrative and judicial issues it is published five times per year and is available by subscription. Also known as the Red Journal.

The Tax Specialist covers the latest issues affecting your role and your business, including:

  • consolidations
  • mergers and acquisitions
  • international tax
  • GST securitisation
  • venture capital
  • legal professional privilege
  • Part IVA
  • TOFA, and more.

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Articles from the current issue:

  • Section 100A: The case that needs to run

    shopping_cart Add to cart 01 Feb 2021

    The meaning of “ordinary family or commercial dealing” in s 100A is unclear. This article demonstrates that the reasons for decision of Hill and Sackville JJ in Prestige Motors point the way to the meaning of the phrase — it gives rise to a dominant purpose test. However, the task for taxpayers is not simple because s 100A was intended to have a broad application; to that end, the dominant purpose test will only be considered after tax avoidance has been presumed.

  • Transfer pricing and intangibles – part 1: Analysing intangibles under Subdivision 815-B

    shopping_cart Add to cart 01 Feb 2021

    The analysis of intangibles under domestic transfer pricing rules and international transfer pricing guidelines continues to be a high priority area for tax jurisdictions, tax administrations and multinational enterprise (MNE) groups. These rules continue to evolve driven by the ever-increasing portion of the overall value of many MNE groups represented by intangibles and ongoing perceptions that profits are not being taxed in the jurisdiction where value is being added. This article considers the analysis of intangibles under Subdiv 815-B of the Income Tax Assessment Act 1997 and under the 2017 OECD transfer pricing guidelines. Part 1 considers the interpretation of the transfer pricing rules in Subdiv 815-B for the purposes of analysing intangibles. Part 2 will consider the analysis of intangibles under the 2017 OECD transfer pricing guidelines and include a number of case studies intended to highlight potential significant differences with Subdiv 815-B. Finally, part 3 will consider the valuing of intangibles for the purposes of Subdiv 815-B and the 2017 OECD transfer pricing guidelines (including the new concept of hard-to-value intangibles).

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