House of Representatives

Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015

Explanatory Memorandum

(Circulated by the authority of the Treasurer, the Hon J. B. Hockey MP)

[1]
See for example the arguments raised in previous cases such as Commissioner of Taxation v Consolidated Press Holdings Ltd [2001] HCA 32, [95].

[2]
http://www.oecd.org/ctp/preventing-the-granting-of-treaty-benefits-in-inappropriate-circumstances-9789264219120-en.htm

[3]
See for example the arguments raised in previous cases such as Noza Holdings Pty Ltd v Commissioner of Taxation [2011] FCA 46.

[4]
See paragraph 1.118 of the Explanatory Memorandum to the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013.

[5]
See paragraph 1.111 of the Explanatory Memorandum to the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013.

[6]
OECD, Addressing Base Erosion and Profit Shifting (2013).

[7]
Treasury, Risks to the Sustainability of Australia's Corporate Tax Base (July 2013) page 45.

[8]
Page 49

[9]
Page 48


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