TITLE

'Send a strong man to England - capacity to put up a fight more important than intimate knowledge of income tax acts and practice': Australia and the development of the dominion income tax relief system of 1920

AUTHOR(S)
Taylor, C. John
PUB. DATE
June 2014
SOURCE
eJournal of Tax Research;Jun2014, Vol. 12 Issue 1, p32
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
The system of Dominion Income Tax Relief, which operated between the United Kingdom and Australia between 1st July 1921 and 30th June 1946, offered a solution to the problem of international juridical double taxation which differed in significant respects from the solution subsequently developed in bi-lateral double taxation treaties. The system allowed a country taxing on the basis of residence (in this case the United Kingdom) to give a credit for underlying foreign tax paid on dividends irrespective of the nature and extent of the shareholding in the foreign company. More fundamentally the system required a sharing of the obligation to relieve international juridical double taxation between the residence and source country that did not depend on a differential treatment of particular categories of income. Using the archival sources that have been available to the author this paper examines: (1) the views of the then Australian Commissioner of Taxation on the problem; (2) the effect that submissions by the Australian representative (the Commonwealth Statistician) at a conference of Dominion representatives with the Sub Committee of the United Kingdom Royal Commission had on the scheme of Dominion Income Tax; and (3) the reasons for the subsequent demise of the scheme.
ACCESSION #
97023283

 

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