Skip to main content

Your shopping cart is empty

Concepts of residence and source into the 21st century seminar paper


The concepts of residence and source are fundamental to the design of taxation structures. Theoretically a country can levy taxes on any person it chooses with respect to any economic activity or asset and wherever situated. But the pragmatic problems of enforcement with respect to subjects or objects of taxation beyond the borders of a country have led to the establishment of two basic principles which determine fiscal structures: the source principle and the residence principle.

Author profile:

Hon Ian Gzell AM FTI-Life
Mr Gzell was admitted to the Queensland Bar in 1965 and was appointed Queen's Counsel in 1977. He sat on the Equity Division of the Supreme Court of New South Wales from 2002 until his retirement in 2013. Apart from his other duties, he was the Revenue List Judge. He was admitted as a Barrister in every state and territory of Australia and in New Zealand and Papua New Guinea, with admissions for multiple single causes in Singapore, Fiji and the Solomon Islands. At the Bar, Mr Gzell specialised in revenue law with particular emphasis on international taxation. He was President of The Tax Institute from 1985-1986 and President of the Commercial Law Association of Australia from 1994-1996. He was Chairman of the Society of Trust and Estate Practitioners Australia and of its New South Wales branch from 2007-2013. He was a Council Member of the Society World Wide from 2011-2013. In 2012 Mr Gzell was appointed President of The International Academy of Estate and Trust Law. He has had numerous articles published and is in constant demand as a speaker. Current at 16 February 2015 Click here to expand/collapse more articles by The Hon. Justice Ian GZELL.

This was presented at International Tax into the 21st Century.

Get a 20% discount when you buy all the items from this event.

Individual sessions

Cross border leasing - asymmetrical taxation treatment

Author(s):  Oliver YATES

Materials from this session:

Concepts of Residence & Source into the 21st Century

Author(s):  The Hon. Justice Ian GZELL

Materials from this session:

Outbound investment - listed countries

Author(s):  Tony CLEMENS

Materials from this session:

Outbound investments

Author(s):  Peter DIMECH,  David SCOTT

Materials from this session:

Foreign tax credits - past, present and future

Author(s):  Richard SHADDICK

Materials from this session:

Inbound investments

Author(s):  Grant MILLARD

Materials from this session:

Developments in international tax law

Author(s):  Richard J VANN

Materials from this session:

Dealing with dividend streams

Author(s):  Tony PANE

Materials from this session:

ATO's approach to international tax into the future

Author(s):  Jim KILLALY

Materials from this session:

Further details about this event:


Copyright Statement