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The times they are a-changing: Recent developments in Australia’s international tax rules


A lot has happened in international tax in 2017. There has been an escalation in new tax developments, with significant changes happening within Australia’s international tax rules. Change is likely to continue as states sign up to the various multilateral agreements such as the common reporting standard (CRS) and country-by-country (CbC) reporting and to the multilateral instrument. This article provides an overview of the recent developments and potential changes to come in respect of: transparency and the public disclosure of tax information; taxation informationgathering regimes, which include the CRS, the proposed mandatory reporting regime and CbC reporting; selected transfer pricing developments; and tax treaties, including the impact of the 2017 Multilateral Convention, the 2017 OECD Model Tax Convention on Income and on Capital and the 2016 Australia–Germany comprehensive tax treaty. It is expected that in the foreseeable future, more changes are to come.


Author profiles

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 29 October 2012
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Brett Bondfield CTA
Brett is a Lecturer in the Business Law, Faculty of Economics and Business, University of Sydney. - Current at 01 July 2011
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