Australian Tax Review (AT Rev)
Critical evaluation of Australian and international tax law
About the Journal
Since 1971, the Australian Tax Review (ISSN: 0311-094X) has been providing in-depth analysis of current tax issues in the Australian tax environment in all areas of tax law, recent cases and legislative developments.
The journal has a national and international reputation which services both the academic and professional tax law markets. Contributors include Justices of the Federal Court, the Commissioner of Taxation, and senior practitioners and academics from Australia and overseas.
Being a fully refereed journal, articles are only accepted for publication after a rigorous peer review process. Appropriate referees (a minimum of two for each article submitted) are selected by the editors from the ranks of senior Australian and international tax academics and practitioners.
Professor Dale Pinto, Head of the Taxation Department, Curtin Law School, Curtin University, Western Australia
Professor Kerrie Sadiq, School of Accountancy, QUT Business School, Queensland University of Technology
Editorial Board Members
Professor Catherine Brown, Faculty of Law, University of Calgary
Michael D’Ascenzo AO, Adjunct Professor, University of Melbourne and University of New South Wales; former Commissioner, Australian Taxation Office
Professor Chris Evans, Professor, School of Accounting, Auditing and Taxation, UNSW
Professor Judith Freedman, Faculty of Law, Oxford University
The Hon Justice Michelle Gordon, High Court of Australia
Professor Richard Krever AM, Professor, Law School, University of Western Australia
The Hon Sir Anthony Mason AC, KBE, Barrister; former Chief Justice of the High Court of Australia
Professor Ann O’Connell, Melbourne Law School, The University of Melbourne
The Hon Tony Pagone QC, Victorian Bar
Professor John Prebble, Faculty of Law, Victoria University, Wellington
Professor Joel Slemrod, Ross School of Business, University of Michigan
Tony Slater QC, Barrister, Sydney
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For the individual contents pages for each Part, click here.
The latest Part of the Australian Tax Review includes the following articles: “The Taxation of Both Sides of Take-or-Pay Contracts” – Hon Richard Edmonds AM SC; “A Cautionary Application of the Myer Emporium Principle to Deductions” – Alexander Schatz; and “What Does It Take to Make a House New?” – Christine Peacock. Also in this Part are the following sections: Editorial; and Book Review: “Taxation of Charities and Not-for-profits”, by Ann O’Connell – Reviewed by Anne Robinson AM and Jae Yang.
The latest Part of the Australian Tax Review includes the following articles: “The Oracle, Transparent Entities and Access to Tax Treaties” – Mark Brabazon SC; “Impact of the Multilateral Instrument on the Interpretation of Australia’s Income Tax Treaties” – Peter Stinson; “Deducting Hybrid Mismatch Rules – Fit for Purpose?” – Buck Xiao and Anna Bullimore; and “Digital Services Taxes and the Unified Approach under the Pillar One Proposal: Exploring the Nexus Frameworks Through the Example of Alibaba” – Victoria Plekhanova. Also in this Part is an Editorial: “Special Issue on International Tax” – Antony Ting.
The latest Part of the Australian Tax Review includes an Editorial and the following articles: “Justice Hill Memorial Lecture 2020: The Judicial Work of the Hon Justice Edmonds” – Hon Justice Steward; “Double Taxation Agreements: Shield or Sword?” – Joseph Tranzillo; “Taxation of Live Stock in Australia: A Critical Review of Tax Law and Policy” – Christina Allen; and “BHP in the High Court: An Analysis of the Court’s Reasons” – Hon Richard Edmonds AM SC.
The latest Part of the Australian Tax Review includes an Editorial and the following articles: “Deemed Dividend Rules: Tax-Free Extraction of Profits from Companies and Exploitation of Structural Foundations of the Income Tax Regime” – Dale Boccabella and Kayleen Manwaring; “Pro Bono Tax Clinics: An International Comparison and Framework for Evidence-based Evaluation” – A Kayis-Kumar, J Noone, F Martin and M Walpole; and “Multi-cell Entities and the Duties Act 1997 (NSW): Practical Considerations” – Cullen Smythe. Also in this Part is a Case Note: “Elucidating Myer Emporium and Characterising Isolated Transactions: Greig v Commissioner of Taxation” – Benjamin Teng.
The latest Part of the Australian Tax Review includes an Editorial, and the following articles: “Taxpayer Attitudinal Responses to Tax Audits – Strategic Implications of Recent Findings from the United States” – John Bevacqua; “Preventing Pension Double Taxation: The Treatment of Australian Superannuation Guarantee under the Existing Australia-US Tax Treaty” – KE Powell; and “When Is There an “Adventure or Concern in the Nature of Trade” for GST Purposes?” – Rami Hanegbi.
The latest Part of the Australian Tax Review includes an Editorial, and the following articles: “Australia’s System for Relieving Foreign Source Income from Double Taxation: Yesterday, Today and Tomorrow” – The Hon Richard Edmonds AM SC; and “Digitalisation and Broadcasting: Evaluating the Application of Royalty Withholding Tax to Digitalised Business Models” – Celeste M Black.
The latest Part of the Australian Tax Review includes an Editorial, and the following articles: “The Application of Australia’s Domestic Tax Laws and Tax Treaties Where a Foreign Company is a Resident” – Norman Hanna; “Streaming of Franking Credits Curtailed by Bamford-Induced Amendments – an Unintended Consequence?” – Brett Freudenberg and Dale Boccabella; and “Tax Implications of Intangibles in the World of the BEPS: Do APAs Still Have a Role to Play in the Tax Planning Strategies of Multinationals?” – Ranjana Gupta.
The latest Part of the Australian Tax Review includes an Editorial, and the following articles: “The “Sufficiently Influenced” Benchmark for a Company to Be an Associate of Another Company: An Analysis of the BHP Case” – The Hon Richard Edmonds AM SC; “The Deductibility of Tax-related Expenses: Historical and Comparative Perspectives” – Ann Kayis-Kumar, Peter Mellor and Chris Evans; “Doing the BEPS We Can? Addressing Distortions in the Cross-border Intercompany Setting” – Ann Kayis-Kumar; and “Non-Competition Agreements and the Capital/Revenue Distinction: A Comparative Analysis” – Meena Hanna.
The latest Part of the Australian Tax Review includes the following articles: “Where Are All the Women in Tax?” – Ann O’Connell; “Laws to Protect Tax Whistleblowing in Australia: What Does This Mean for Taxpayers and the Taxation Profession?” – John McLaren; and “The Design Elements of Flow-Through Taxation” – Alex Evans. There is also an Editorial; and a Book Review: “Back to the Future: Double Taxation and the League of Nations” by Sunita Jogarajan – Reviewed by Gareth Redenbach.
The latest Part of the Australian Tax Review includes the following articles: “Combatting serious tax non-compliance: Tax fraud and money laundering” – Celeste Black; “A proposed statutory remedial power for the Commissioner of Taxation: A Henry VIII Clause to benefit taxpayers?” – Nicole Wilson-Rogers; “Related schemes and section 974-80: a close reading of the Board of Taxation’s proposed amendments” – Antony Faisandier. There is also an Editorial; a Case Note, “Nell Group NV (in liq) v Western Australia (2016) 90 ALJR 655;  HCA 21”, by Jared Clements; and an Obituary tribute to the late Vale Geoffrey Hart, written by Cynthia Coleman.