Edited by Kerrie Sadiq, Professor, Faculty of Business and Law, Queensland University of Technology, Chris Evans, Emeritus Professor, School of Accounting, Auditing and Taxation, UNSW Sydney, Australia and Extraordinary Professor, Department of Taxation, University of Pretoria, South Africa and Na Li, Faculty of Business and Law, Queensland University of Technology, Australia

‘This book is an outstanding introduction to the most pressing current issues in taxation. It includes contributions on a variety of hot topics from the most eminent scholars in the field. It is a must-read for policymakers, lawyers, economists and accountants interested in current debates about tax policy.’

• ContentsForeword by Richard Krever xii1 Introduction: setting the scene 1Kerrie Sadiq, Chris Evans and Na LiPART I FUNDAMENTAL ISSUES IN TAX LAW AND POLICY2 Should we tax income or consumption? 11Victor Thuronyi3 Taxes covered: recent developments on Article 2 of the OECDModel Tax Convention 29Michael Lang4 The future of the corporate form in income tax: a case studyof Canada 53Jinyan Li5 Twenty years since GST reform in Australia: a criticalassessment 74Binh Tran-Nam and Mahmoud AbdellatifPART II INTERNATIONAL TAX ABUSE AND CORPORATEBEHAVIOUR6 International tax minimization: the role of corporate taxmorality 100Kerrie Sadiq7 Applying exit taxes: issues in the financial valuation andaccounting recognition of transferred assets 123António MartinsPART III INTERNATIONAL TAX: BEPS AND BEYOND8 What’s the problem that prompted Pillar Two and is there abetter solution? 140J. Clifton Fleming Jr, Robert J. Peroni and Stephen E. Shay9 BEPS, Pillar Two and developing countries: combating therace to the bottom 152Catherine Brown10 Global tax governance in international tax law-making: insearch of legitimacy and inclusiveness 168Irma Mosquera Valderrama11 Domestic judicial transplants of OECD interpretive solutionsor principles 193Carlo GarbarinoPART IV TAX SPECIFICS12 Taxing and not taxing: the problematic nature of taxconcessions for charities and not-for-profit entities in Australia 217Ann O’Connell13 Energy and taxation 247Marco GreggiPART V TAX REFORM: LESSONS FOR THE FUTURE14 The New Zealand general anti-avoidance rule: sharpening anold blade on the jurisprudential whetstone 269Craig Elliffe15 History informing the future: can we improve tax policyand legislation with respect to taxing capital gains? A NewZealand perspective 286Adrian Sawyer

Edited by Kerrie Sadiq, Professor, Faculty of Business and Law, Queensland University of Technology, Chris Evans, Emeritus Professor, School of Accounting, Auditing and Taxation, UNSW Sydney, Australia and Extraordinary Professor, Department of Taxation, University of Pretoria, South Africa and Na Li, Faculty of Business and Law, Queensland University of Technology, Australia

‘This book is an outstanding introduction to the most pressing current issues in taxation. It includes contributions on a variety of hot topics from the most eminent scholars in the field. It is a must-read for policymakers, lawyers, economists and accountants interested in current debates about tax policy.’

• ContentsForeword by Richard Krever xii1 Introduction: setting the scene 1Kerrie Sadiq, Chris Evans and Na LiPART I FUNDAMENTAL ISSUES IN TAX LAW AND POLICY2 Should we tax income or consumption? 11Victor Thuronyi3 Taxes covered: recent developments on Article 2 of the OECDModel Tax Convention 29Michael Lang4 The future of the corporate form in income tax: a case studyof Canada 53Jinyan Li5 Twenty years since GST reform in Australia: a criticalassessment 74Binh Tran-Nam and Mahmoud AbdellatifPART II INTERNATIONAL TAX ABUSE AND CORPORATEBEHAVIOUR6 International tax minimization: the role of corporate taxmorality 100Kerrie Sadiq7 Applying exit taxes: issues in the financial valuation andaccounting recognition of transferred assets 123António MartinsPART III INTERNATIONAL TAX: BEPS AND BEYOND8 What’s the problem that prompted Pillar Two and is there abetter solution? 140J. Clifton Fleming Jr, Robert J. Peroni and Stephen E. Shay9 BEPS, Pillar Two and developing countries: combating therace to the bottom 152Catherine Brown10 Global tax governance in international tax law-making: insearch of legitimacy and inclusiveness 168Irma Mosquera Valderrama11 Domestic judicial transplants of OECD interpretive solutionsor principles 193Carlo GarbarinoPART IV TAX SPECIFICS12 Taxing and not taxing: the problematic nature of taxconcessions for charities and not-for-profit entities in Australia 217Ann O’Connell13 Energy and taxation 247Marco GreggiPART V TAX REFORM: LESSONS FOR THE FUTURE14 The New Zealand general anti-avoidance rule: sharpening anold blade on the jurisprudential whetstone 269Craig Elliffe15 History informing the future: can we improve tax policyand legislation with respect to taxing capital gains? A NewZealand perspective 286Adrian Sawyer

Edited by Kerrie Sadiq, Professor, Faculty of Business and Law, Queensland University of Technology, Chris Evans, Emeritus Professor, School of Accounting, Auditing and Taxation, UNSW Sydney, Australia and Extraordinary Professor, Department of Taxation, University of Pretoria, South Africa and Na Li, Faculty of Business and Law, Queensland University of Technology, Australia

‘This book is an outstanding introduction to the most pressing current issues in taxation. It includes contributions on a variety of hot topics from the most eminent scholars in the field. It is a must-read for policymakers, lawyers, economists and accountants interested in current debates about tax policy.’

• ContentsForeword by Richard Krever xii1 Introduction: setting the scene 1Kerrie Sadiq, Chris Evans and Na LiPART I FUNDAMENTAL ISSUES IN TAX LAW AND POLICY2 Should we tax income or consumption? 11Victor Thuronyi3 Taxes covered: recent developments on Article 2 of the OECDModel Tax Convention 29Michael Lang4 The future of the corporate form in income tax: a case studyof Canada 53Jinyan Li5 Twenty years since GST reform in Australia: a criticalassessment 74Binh Tran-Nam and Mahmoud AbdellatifPART II INTERNATIONAL TAX ABUSE AND CORPORATEBEHAVIOUR6 International tax minimization: the role of corporate taxmorality 100Kerrie Sadiq7 Applying exit taxes: issues in the financial valuation andaccounting recognition of transferred assets 123António MartinsPART III INTERNATIONAL TAX: BEPS AND BEYOND8 What’s the problem that prompted Pillar Two and is there abetter solution? 140J. Clifton Fleming Jr, Robert J. Peroni and Stephen E. Shay9 BEPS, Pillar Two and developing countries: combating therace to the bottom 152Catherine Brown10 Global tax governance in international tax law-making: insearch of legitimacy and inclusiveness 168Irma Mosquera Valderrama11 Domestic judicial transplants of OECD interpretive solutionsor principles 193Carlo GarbarinoPART IV TAX SPECIFICS12 Taxing and not taxing: the problematic nature of taxconcessions for charities and not-for-profit entities in Australia 217Ann O’Connell13 Energy and taxation 247Marco GreggiPART V TAX REFORM: LESSONS FOR THE FUTURE14 The New Zealand general anti-avoidance rule: sharpening anold blade on the jurisprudential whetstone 269Craig Elliffe15 History informing the future: can we improve tax policyand legislation with respect to taxing capital gains? A NewZealand perspective 286Adrian Sawyer