Private Bag 92019
Auckland Mail Centre
Auckland, 1142
New Zealand
University of Auckland - Faculty of Law
SSRN RANKINGS
in Total Papers Downloads
general anti-avoidance, double tax agreements, cross border transactions
tax treaties, international tax, anti-avoidance rules, treaty overrides, specific anti-avoidance rules
international, tax avoidance, GAAR, certainty of law, factual and interpretative, domestic law overriding treaties
tax avoidance, criminal tax avoidance, criminal tax prosecution, tax fraud, New Zealand tax avoidance, New Zealand tax fraud
tax evasion, pecuniary advantage, prosecution for tax offences, tax fraud, tax offences
Beneficial ownership, Double Tax agreements, Articles 10,11, and 12, Article 3(2)
New Zealand tax avoidance, Supreme Court, Ben Nevis, Glenharrow, Westpac, BNZ, Penny and Hooper, section BG1, Parliamentary Contemplation
permanent establishment, Knights of Columbus, agency, fixed place of business, right of disposition
Treaty override, treaty abuse, tax avoidance, Google tax, digital economy, unilateral tax change, dualist legal system, monist legal system
tax reform, New Zealand, capital gains tax, South Africa, evidence of costs and benefits, realization based capital gains
hybrid, entities, limited partnerships, Australian tax treaty, New Zealand tax treaty, double taxation, partnership report
resident of a treaty, foreign trust, interpretation of treaties, New Zealand trustees, treaty benefits
thin capitalisation, tax treaties, non-discrimination article, Article 24, anti-avoidance, do treaties override thin capitalisation rules
taxation of non-resident capital gains, Article 13, capital gains tax, treaty shopping
anti-avoidance rules, tax treaties, 2003 Commentary, Article 1, interpretation of tax treaties, use of Commentaries
General anti-avoidance rule, GAAR, tax avoidance, judge made law, statutory interpretation, certainty of law, integrity of the tax system
thin capitalisation, non-discrimination articles, article 24 OECD Model, arm's length principles
general anti-avoidance provision, tax avoidance, artificial and uncommercial arrangements
foreign tax credits, exemption, credit, controlled foreign companies, double taxation, imputation systems
tax reform, New Zealand, capital gains tax, horizontal equity, generic problems in the NZ rax system
definition of income tax, capital gains, Virgin Holdings SA, taxation of movable property, static interpretation, New Zealand tax reform
general anti-avoidance rule, New Zealand, cross border instrument, hybrid instrument, optional convertible note
residency, dual residency, permanent home, centre of vital interests, management and control
New Zealand, Tax avoidance, GAAR, Court of Appeal, Supreme Court
Hybrid entities, partnership report, treaty entitlement, distributive rules, employment income, directors fees, foreign tax credits
gross-up of tax, cost of borrowing, impact of tax on costs of borrowing
thin capitalisation rules, non-discrimination, article 24, double tax treaties, fixed ratio safe harbour thresholds
repairs and maintenance, deductions in respect of leaky buildings, capital and revenue
principal purpose test, treaty abuse, tax avoidance, multilateral instrument
interpretation of tax treaties, tax sparing, tax credits, vienna convention on the law of treaties, textual interpretation, purposive interpretation
associated persons, New Zealand anti-avoidance provisions, tax reform
