Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation
Against the background of a global focus on base erosion and profit shifting and well-publicised cases of high profile multinationals minimising their taxable burden in high tax jurisdictions, including the use of transfer pricing as a major tax minimisation strategy, this paper argues for a reconce...
| Main Authors: | , |
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| Format: | Journal Article |
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University of New South Wales, Faculty of Law. Atax
2015
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| Online Access: | https://www.business.unsw.edu.au/research-site/publications-site/ejournaloftaxresearch-site/Documents/eJTR_Vol13_No2_2015.pdf http://hdl.handle.net/20.500.11937/6601 |
| _version_ | 1848745123671703552 |
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| author | Wilson-Rogers, Nicole Pinto, Dale |
| author_facet | Wilson-Rogers, Nicole Pinto, Dale |
| author_sort | Wilson-Rogers, Nicole |
| building | Curtin Institutional Repository |
| collection | Online Access |
| description | Against the background of a global focus on base erosion and profit shifting and well-publicised cases of high profile multinationals minimising their taxable burden in high tax jurisdictions, including the use of transfer pricing as a major tax minimisation strategy, this paper argues for a reconceptualisation of Australia’s Transfer Pricing rules by adopting an approach based on using economic presence as a basis for source based taxation.The approach of the paper is to first discuss and evaluate the evolution of Australia’s transfer pricing legislation. In this part, it will be argued that the most current reforms to Australia’s transfer pricing regime present several fundamental deficiencies. In response to these deficiencies, the second part of the paper advocates a policy response focused on a reconceptualised version of current source rules applying economic presence as a foundation for taxation. |
| first_indexed | 2025-11-14T06:12:21Z |
| format | Journal Article |
| id | curtin-20.500.11937-6601 |
| institution | Curtin University Malaysia |
| institution_category | Local University |
| last_indexed | 2025-11-14T06:12:21Z |
| publishDate | 2015 |
| publisher | University of New South Wales, Faculty of Law. Atax |
| recordtype | eprints |
| repository_type | Digital Repository |
| spelling | curtin-20.500.11937-66012017-01-30T10:54:07Z Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation Wilson-Rogers, Nicole Pinto, Dale Against the background of a global focus on base erosion and profit shifting and well-publicised cases of high profile multinationals minimising their taxable burden in high tax jurisdictions, including the use of transfer pricing as a major tax minimisation strategy, this paper argues for a reconceptualisation of Australia’s Transfer Pricing rules by adopting an approach based on using economic presence as a basis for source based taxation.The approach of the paper is to first discuss and evaluate the evolution of Australia’s transfer pricing legislation. In this part, it will be argued that the most current reforms to Australia’s transfer pricing regime present several fundamental deficiencies. In response to these deficiencies, the second part of the paper advocates a policy response focused on a reconceptualised version of current source rules applying economic presence as a foundation for taxation. 2015 Journal Article http://hdl.handle.net/20.500.11937/6601 https://www.business.unsw.edu.au/research-site/publications-site/ejournaloftaxresearch-site/Documents/eJTR_Vol13_No2_2015.pdf University of New South Wales, Faculty of Law. Atax fulltext |
| spellingShingle | Wilson-Rogers, Nicole Pinto, Dale Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation |
| title | Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation |
| title_full | Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation |
| title_fullStr | Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation |
| title_full_unstemmed | Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation |
| title_short | Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation |
| title_sort | reconceptualising australia’s transfer pricing rules: an approach based on adopting economic presence as a basis for taxation |
| url | https://www.business.unsw.edu.au/research-site/publications-site/ejournaloftaxresearch-site/Documents/eJTR_Vol13_No2_2015.pdf http://hdl.handle.net/20.500.11937/6601 |