Richard J. Vann

The University of Sydney Law School

Challis Professor of Law

Faculty of Law Building, F10

The University of Sydney

Camperdown, NSW 2006

Australia

http://www.law.usyd.edu.au/about/staff/RichardVann/index.shtml

SCHOLARLY PAPERS

20

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Scholarly Papers (20)

1.

Tax Treaties: The Secret Agent's Secrets

British Tax Review (50th Anniversary Edition), No. 3, p. 345, 2006, Sydney Law School Research Paper No. 06/05
Number of pages: 39 Posted: 27 Jul 2006 Last Revised: 10 Apr 2011
Richard J. Vann
The University of Sydney Law School
Downloads 1,188 (16,360)

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Agents, Australia, Double taxation, International taxation, Permanent establishment, Transfer pricing, Treaties

2.

Transfer Pricing Money – The Chevron Case

ITP @ 20 [1996 – 2016]: CELEBRATING TWENTY YEARS OF THE INTERNATIONAL TAX PROGRAM OF THE NEW YORK UNIVERSITY SCHOOL OF LAW, H.D. Rosenbloom, et al, eds, NYU School of Law, USA, 2016, Sydney Law School Research Paper No. 16/72
Number of pages: 35 Posted: 18 Aug 2016 Last Revised: 27 Mar 2017
Richard J. Vann and Graeme S. Cooper
The University of Sydney Law School and The University of Sydney Law School
Downloads 862 (26,275)

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International taxation, tax treaties, transfer pricing, interest deductibility

3.

Writing Tax Treaty History

HISTORY OF TAX TREATIES, M. Lang, E. Reimer, eds., Nomos, Forthcoming, Sydney Law School Research Paper No. 10/19
Number of pages: 17 Posted: 24 Mar 2011
Richard J. Vann
The University of Sydney Law School
Downloads 852 (26,722)

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Double Taxation, History, International Taxation, League of Nations, OECD, Tax Treaties

4.

'Liable to Tax' and Company Residence under Tax Treaties

RESIDENCE OF COMPANIES UNDER TAX TREATIES AND EC LAW, EC AND INTERNATIONAL TAX LAW SERIES, Vol. 5, pp. 197-271, G. Maisto, ed., IBFD: The Netherlands, 2009, Sydney Law School Research Paper No. 10/131
Number of pages: 77 Posted: 24 Nov 2010
Richard J. Vann
The University of Sydney Law School
Downloads 671 (37,097)

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Business income, Corporate taxation, Double taxation, History, International taxation, League of Nations, OECD, Permanent establishment, Residence, Transfer pricing, Tax treaties, Treaty shopping

5.

Beneficial Ownership: What Does History (and Maybe Policy) Tell Us

Sydney Law School Research Paper No. 12/66
Number of pages: 55 Posted: 10 Sep 2012
Richard J. Vann
The University of Sydney Law School
Downloads 611 (41,941)

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beneficial owner, tax treaties, international taxation, history

6.

Reflections on Business Profits and the Arm’s-Length Principle

THE TAXATION OF BUSINESS PROFITS UNDER TAX TREATIES, pp. 133-169, B.J. Arnold, J. Sasseville, E.M. Zolt, eds., Canadian Tax Foundation, 2003, Sydney Law School Research Paper No. 10/127
Number of pages: 38 Posted: 19 Nov 2010
Richard J. Vann
The University of Sydney Law School
Downloads 578 (45,173)

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Business Restructures, Corporate Taxation, Double Taxation, International Taxation, Permanent Establishment, Residence, Transfer Pricing, Tax Treaties

7.

Policy Forum: The Policy Underpinnings of the BEPS Project-Preserving the International Corporate Income Tax?

Canadian Tax Journal, Vol. 62, No. 2, pp. 433-441, 2014, Sydney Law School Research Paper No. 14/77
Number of pages: 11 Posted: 22 Aug 2014 Last Revised: 01 Sep 2014
Richard J. Vann
The University of Sydney Law School
Downloads 547 (48,481)

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BEPS, corporate taxes, international taxation, tax policy

8.

A Model Tax Treaty for the Asian-Pacific Region?

Bulletin for International Fiscal Documentation, Vol. 45, pp. 99-111, 1991, APTIRC Bulletin, Vol. 8, pp. 392-422, 1990, ANTI-AVOIDANCE AND TAX TREATY POLICIES AND PRACTICE IN THE ASIAN-PACIFIC REGION, D. O’Reilly, ed., APTIRC, 1990, Sydney Law School Research Paper No. 10/122
Number of pages: 50 Posted: 08 Nov 2010
Richard J. Vann
The University of Sydney Law School
Downloads 493 (55,294)

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Corporate Groups, Double taxation, History, International Taxation, International Trade, League of Nations, OECD, Transfer Pricing, Tax Treaties

9.

Travellers, Tax Policy and Agency Permanent Establishments

British Tax Review, No. 6, pp. 538-553, 2010, Sydney Law School Research Paper No. 11/01
Number of pages: 17 Posted: 11 Jan 2011
Richard J. Vann
The University of Sydney Law School
Downloads 374 (77,204)

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OECD, agents, foreign travel, permanent establishment, tax principles, travellers

10.

Current Trends in Balancing Residence and Source Taxation

BRICS AND THE EMERGENCE OF INTERNATIONAL TAX COORDINATION, Y. Brauner, P. Pistone, eds, IBDF, The Netherlands, 2015, Sydney Law School Research Paper No. 14/107
Number of pages: 19 Posted: 15 Dec 2014 Last Revised: 31 Mar 2016
Richard J. Vann
The University of Sydney Law School
Downloads 312 (95,204)

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BEPS, corporate taxes, international taxation, tax policy, developing countries

11.

Do We Need 7(3)? History and Purpose of the Business Profits Deduction Rule in Tax Treaties

STUDIES IN THE HISTORY OF TAX LAW, J. Tiley, ed., Hart Publishing, Forthcoming, Sydney Law School Research Paper No. 10/18
Number of pages: 31 Posted: 22 Mar 2011
Richard J. Vann
The University of Sydney Law School
Downloads 261 (114,781)

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OECD, permanent establishment, business profits, international taxation, deductions, transfer pricing, treaties

12.

Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, with Respect to Fiscally Transparent Entities

British Tax Review, Vol. 2017, No. 3, pp. 295-373, 2017, Bulletin for International Taxation, Part 1, Vol. 71, No. 9, pp. 475-503, 2017, Bulletin for International Taxation, Part 2, Vol. 71, No. 10, pp. 553-567, 2017, Sydney Law School Research Paper No. 17/59
Number of pages: 81 Posted: 20 Jul 2017 Last Revised: 31 Oct 2017
Ernst & Young, CMS Bureau Francis Lefebvre, London School of Economics & Political Science (LSE) - London School of Economics, Field Court Tax Chambers, KPMG Washington National Tax Practice, University of Lausanne, BMR Advisors, University of Cape Town (UCT) - Faculty of Law, Jones Day - Tokyo Office, PriceWaterhouseCoopers LLP - PricewaterhouseCoopers GmbH, Catholic University of the Sacred Heart of Milan - Catholic University of the Sacred Heart of Piacenza, Adachi Henderson Miyatake & Fujita, Leiden University, The University of Sydney Law School and Uppsala University
Downloads 249 (120,505)

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International tax, tax treaties, BEPS, fiscally transparent entities

13.

Interpretation of Tax Treaties in New Holland

A TAX GLOBALIST: ESSAYS IN HONOUR of MAARTEN J. ELLIS, pp. 144-162, H. van Arendonk, F. Engelen, S. Jansen, eds., IBFD: Amsterdam, 2005, Sydney Law School Research Paper No. 10/121
Number of pages: 12 Posted: 09 Nov 2010
Richard J. Vann
The University of Sydney Law School
Downloads 240 (125,084)

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Australia, International taxation, Interpretation, Tax treaties, Vienna Convention on Treaties

14.

Regulation and Reforms to Enhance Financial Stability in the Post-GFC Era

CIFR Paper No. 036/2014
Number of pages: 55 Posted: 11 Aug 2014 Last Revised: 03 Sep 2014
The University of Sydney Law School, The University of Sydney Law School, The University of Sydney Law School, The University of Sydney Law School, The University of Sydney Law School, The University of Sydney Law School and The University of Sydney Law School
Downloads 230 (130,528)

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15.

Corporate Tax Reform in Australia: Lucky Escape for Lucky Country?

This material was first published by Thomson Reuters (Professional) UK Limited in Vann, R, 'Corporate Tax Reform in Australia: Lucky Escape for Lucky Country?', British Tax Review, 2013, No. 1, pp. 59-75 and is reproduced by agreement with the Publishers, Sydney Law School Research Paper No. 13/34
Number of pages: 18 Posted: 22 Apr 2013
Richard J. Vann
The University of Sydney Law School
Downloads 196 (151,938)

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Australia, tax reform, corporate tax, tax rates, allowance for corporate equity, income tax base broadening

16.

The New Australia-UK Tax Treaty

British Tax Review, No. 3, pp. 194-233, 2004, Sydney Law School Research Paper No. 11/132
Number of pages: 41 Posted: 26 Nov 2010 Last Revised: 10 Apr 2011
Richard J. Vann and J. David B. Oliver
The University of Sydney Law School and University of Cambridge
Downloads 193 (154,168)

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Australia, Double Taxation, International Taxation, OECD, Tax Treaties, United Kingdom

17.

The UN Model and Agents: ‘Wholly or Almost Wholly’

Sydney Law School Research Paper No. 11/62
Number of pages: 9 Posted: 01 Oct 2011
Richard J. Vann
The University of Sydney Law School
Downloads 156 (185,809)

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Agents, Double Taxation, International Taxation, History, Tax Treaties, Permanent Establishment, OECD, UN

18.

Royalties in Australia: Task Technology and Seven Network Cases

TAX TREATY CASE LAW AROUND THE GLOBE 2015, IBFD, The Netherlands, 2016, Sydney Law School Research Paper No. 15/96
Number of pages: 28 Posted: 02 Nov 2015 Last Revised: 31 Mar 2016
Richard J. Vann
The University of Sydney Law School
Downloads 129 (216,813)

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Tax treaties, royalties, Australia

19.

Hybrid Entities in Australia: Resource Capital Fund III LP Case

TAX TREATY CASE LAW AROUND THE GLOBE 2015, IBFD, The Netherlands, 2016, Sydney Law School Research Paper No. 16/09
Number of pages: 17 Posted: 11 Feb 2016 Last Revised: 31 Mar 2016
Richard J. Vann
The University of Sydney Law School
Downloads 101 (258,814)

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Tax treaties, hybrid entities, Australia

20.

The History of Royalties in Tax Treaties 1921-61: Why?

COMPARATIVE PERSPECTIVES ON REVENUE LAW: ESSAYS IN HONOUR OF JOHN TILLEY, pp. 166-196, J. Avery Jones, P. Harris, D. Oliver, eds., Cambridge University Press, 2008, Sydney Law School Research Paper No. 10/143
Posted: 15 Dec 2010 Last Revised: 19 Dec 2010
Richard J. Vann
The University of Sydney Law School

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Double Taxation, History, International Taxation, League of Nations, OECD, Royalties, Tax Treaties