Explanatory Memorandum
(Circulated by the authority of the Treasurer, the Hon J. B. Hockey MP)See for example the arguments raised in previous cases such as Commissioner of Taxation v Consolidated Press Holdings Ltd [2001] HCA 32, [95].
http://www.oecd.org/ctp/preventing-the-granting-of-treaty-benefits-in-inappropriate-circumstances-9789264219120-en.htm
See for example the arguments raised in previous cases such as Noza Holdings Pty Ltd v Commissioner of Taxation [2011] FCA 46.
See paragraph 1.118 of the Explanatory Memorandum to the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013.
See paragraph 1.111 of the Explanatory Memorandum to the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013.
OECD, Addressing Base Erosion and Profit Shifting (2013).
Treasury, Risks to the Sustainability of Australia's Corporate Tax Base (July 2013) page 45.
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