Papers by Michael Walpole
International VAT Monitor, Sep 5, 2011
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The Global Financial Crisis of 2008 left many economies with significant budgetary problems. In t... more The Global Financial Crisis of 2008 left many economies with significant budgetary problems. In the search for revenue, the Organisation for Economic Cooperation and Development (OECD) and the Group of 20 Nations (G20) in 2012 charged the OECD with the ‘Base Erosion and Profit Shifting’ (BEPS) project, examining international tax planning by multinational groups. BEPS has been a major theme in international tax discussion since with the project being opened to non-OECD countries through its ‘inclusive framework’. Progress was rapid with the OECD producing an initial report and an Action Plan in 2013. Subsequently, several reports in OECD countries and in the European Union dealt with issues related to BEPS culminating in the publication of the Final BEPS Reports, the Multilateral Instrument and the 2017 update to the OECD Model Tax Convention.The BEPS project, however, did not end there and remains a work in progress. The focus is now on what has become known as Pillar I and Pillar II which are concerned with tax issues arising from the digitisation of the economy and raise fundamental jurisdictional questions about the relative taxing rights of residence and source countries.Although one of the insights of the BEPS project has been recognition of the need for co-ordinated responses by countries to cross-border tax planning strategies many of the recommendations in the BEPS Final Reports can only be implemented by national legislation. Hence, the need for this publication on Australian international income tax law that analyses the current domestic law and tax treaty provisions and takes into account the recommendations in the BEPS Final Reports.After discussing international tax policy considerations and the historical development of current Australian rules in the introduction, three chapters examine Australian domestic law rules that apply in the absence of a double tax treaty. Australian double tax treaties and their effect on domestic law are then analysed in Chapter 5. The final two chapters discuss Australian international anti-avoidance provisions and administrative aspects of Australian international taxation. This book provides a thorough discussion of current Australian international tax rules and their implications for taxpayers
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Social Science Research Network, 2014
This article reports on, and draws conclusions from, an investigation designed to gain insights i... more This article reports on, and draws conclusions from, an investigation designed to gain insights into the extent to which tax is a motivator when large multinational companies choose where to develop, and ultimately locate valuable intellectual property (IP). The research undertaken by the authors set out to 1) answer a broad question about specific business behaviour - what influences a multinational company’s choice of location of valuable - IP; 2) elicit attitudes towards Research and Development (RD and 3) assess current schools of thought, tax rules and policy in light of the findings, to determine whether they are effective and desirable. The project arises from previous research by the team members and aims to advance understanding of the extent to which tax rules influence the choice of location of IP.
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Fiscal Publications eBooks, 2005
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The British Tax Review, 2007
Macquarie University ResearchOnline.
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Australian Tax Forum, 1998
The paper reports on major empirical research into Australian compliance costs recently undertake... more The paper reports on major empirical research into Australian compliance costs recently undertaken for the ATO. The research considers the total costs of taxpayer compliance with Federal<br>taxation in Australia in the 1994-95 year of income. It builds upon earlier research into incremental compliance costs, carried out for the ATO by the same ATAX research team.<br><br>The research utilises a survey of just over 10, 000 personal and business taxpayers, together with data provided by the ATO and other sources, to present a clear picture of the magnitude and distribution of compliance costs in Australia in the 1994-95 year of income. It takes into account not only the time and monetary costs expended on compliance, but also quantifies factors such as the value of the tax deduction available to taxpayers and the value of cash flow benefits (and sometimes costs) to taxpayers which can serve to offset taxpayer compliance costs.<br><br>The paper details the major outcomes of the research, and provides a comparison of the level of compliance costs revealed by this latest research with similar research carried out in Australia<br>and overseas.
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Australian Tax Research Foundation eBooks, 1999
This Report examines the extent to which OECD members use taxation impact statements as part of t... more This Report examines the extent to which OECD members use taxation impact statements as part of the process of developing tax policies and legislation. Taxation impact statements are attempts to predict, monitor and control the compliance cost impact of tax changes. The Report also evaluates the effectiveness of such statements where they are used in the OECD, and assesses their role in the Australian context.
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International and Comparative Law Quarterly, Oct 1, 2009
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Social Science Research Network, 2008
This article explores the influence of UK tax concepts on the development of the income tax in Au... more This article explores the influence of UK tax concepts on the development of the income tax in Australia. It shows how certain aspects of the UK's 1842 Income Tax Act found their way initially into the various income taxing provisions enacted by the Australian states in the second half of the nineteenth century and ultimately into the federal income tax provisions that were developed in the first half of the twentieth century. It also shows how that influence was contemporaneously and subsequently reinforced by shared judicial interpretation of sometimes differing legislative provisions. Finally, it identifies the impact of the UK's capital gains tax (CGT) provisions on the development of Australia's own CGT regime in the latter half of the twentieth century, again with sometimes shared jurisprudence. The analysis concludes that while the UK influence is evident, it is only one of a number of powerful factors that have shaped the manner in which income and capital gains are taxed in Australia. The article also argues that the influence is not always direct, and nor is it always one way.
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Social Science Research Network, Apr 1, 2017
The imposition of value‑added tax (VAT) style consumption taxes on so‑called digital supplies is ... more The imposition of value‑added tax (VAT) style consumption taxes on so‑called digital supplies is a challenge that has been made necessary by general trends of globalisation and the change in patterns of supply and consumption in the modern economy. Part of this challenge relates to the complexities associated with the supply of intangibles, and this complexity is exacerbated by the fact that many such supplies take place across international borders. Tax systems have long been attempting to meet such challenges and these efforts have been redoubled as a result of the OECD/G20 motivated base erosion and profit shifting (BEPS) initiatives aimed at reducing opportunities to minimise taxation using cross‑border structures and arrangements. At the same time, the OECD has been proactive in developing guidelines, for application internationally among OECD members, affecting the imposition of the VAT laws. The most common recent efforts to deal with cross‑border supplies of intangibles have been the burgeoning examples of the so‑called “Netflix tax”. This is a tax on consumption that might initially be thought to tax consumption of movies, electronic games and similar forms of entertainment. This article will review the VAT laws applicable to cross‑border provision of so‑called digital supplies in a selection of jurisdictions, namely, Australia, South Africa, New Zealand and Canada. The authors will critically analyse the taxes on digital supplies in those jurisdictions and determine the extent to which they comply with, or depart from, the OECD guidelines.
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Social Science Research Network, Dec 4, 2020
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Social Science Research Network, Oct 16, 2017
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Social Science Research Network, 2019
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Papers by Michael Walpole