Craig Elliffe
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View article: The Quiet Evolution in International Tax: Domestic Law and Double Taxation
The Quiet Evolution in International Tax: Domestic Law and Double Taxation Open
View article: Justifying Source Taxation in the Digital Age
Justifying Source Taxation in the Digital Age Open
I chose to write on a theoretical jurisprudential topic which, in my view, is anchored to a practical problem. In fact, with the rise of the digital economy, it has become the most critical functional problem in the tax world of the 21st c…
View article: The Brave (and Uncertain) New World of International Taxation under the 2020s Compromise
The Brave (and Uncertain) New World of International Taxation under the 2020s Compromise Open
View article: Discerning Commercial and Economic Reality: Applying the GAAR to Frucor
Discerning Commercial and Economic Reality: Applying the GAAR to Frucor Open
View article: International Tax Law and its Influence on National Tax Systems
International Tax Law and its Influence on National Tax Systems Open
View article: Key Practical Issues to Eliminate Double Taxation of Business Income – New Zealand Report to the International Fiscal Association in Paris 2011
Key Practical Issues to Eliminate Double Taxation of Business Income – New Zealand Report to the International Fiscal Association in Paris 2011 Open
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View article: Key Practical Issues to Eliminate Double Taxation of Business Income – New Zealand Report to the International Fiscal Association in Paris 2011
Key Practical Issues to Eliminate Double Taxation of Business Income – New Zealand Report to the International Fiscal Association in Paris 2011 Open
No description supplied
View article: Assessing the Flaws in the 1920s Compromise in the Times of the Burgeoning Digital Economy and the Great Lockdown
Assessing the Flaws in the 1920s Compromise in the Times of the Burgeoning Digital Economy and the Great Lockdown Open
View article: Submission on the Proposed 'Unified Approach' to Pillar One
Submission on the Proposed 'Unified Approach' to Pillar One Open
View article: Interpreting international tax agreements: Alsatia in New Zealand?
Interpreting international tax agreements: Alsatia in New Zealand? Open
This article discusses the current state of tax treaty interpretation in New Zealand with particular reference to a recent decision which has attracted attention both here in New Zealand and overseas. The case concerned whether a New Zeala…
View article: Interest Deductibility: Evaluating the Advantage of Earnings Stripping Regimes in Preventing Thin Capitalisation
Interest Deductibility: Evaluating the Advantage of Earnings Stripping Regimes in Preventing Thin Capitalisation Open
Thin capitalisation regimes are designed to reduce profit shifting from one jurisdiction (the jurisdiction of the borrower where an interest expense is claimed) to another (the jurisdiction of the lender where the income is shifted to). Mo…
View article: New Zealand Branch Report, Subject 1: Assessing BEPS: Origins, Standards and Responses
New Zealand Branch Report, Subject 1: Assessing BEPS: Origins, Standards and Responses Open
View article: The lesser of two evils: Double tax treaty override or treaty abuse?
The lesser of two evils: Double tax treaty override or treaty abuse? Open
On a co-ordinated basis the OECD and G20 are focusing on a far-reaching action plan to combat base erosion and profit shifting (BEPS). Their plans are designed to prevent treaty abuse, foil hybrid mismatches, prevent unusual and aggressive…
View article: Key Issues in the Design of Capital Gains Tax Regimes: Taxing Non-Residents
Key Issues in the Design of Capital Gains Tax Regimes: Taxing Non-Residents Open
This article examines two broad areas of capital gains tax (CGT) design in respect of the taxation of non-residents. The first area relates to the domestic design of the tax and focuses on whether a CGT should apply to all assets held by n…