International tax & business 2017

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

Source: Australian Tax Forum Journal Article

Published Date: 1 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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International tax & business 2017

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