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This chapter analyses the two pillars of the Unified Approach and the Global Anti-Base Erosion Proposals in the light of alternative policy choices which were available to the OECD. These major alternative policy choices include destination-based cash-flow taxation, residual profit allocation by income, formulary apportionment and expanding the concept of permanent establishment. In each case these policies are explained and the advantages and disadvantages of the major policy discussed. Each policy is then analysed to see what it has contributed to the 2020s compromise and what further contribution it might make to international tax reform in the future.What emerges from this analysis is that key elements of the reform owe much to the destination basis of taxation present in the various alternative reform options and selectively adopted in particular by the Unified Approach in Pillar One.
This chapter analyses the two pillars of the Unified Approach and the Global Anti-Base Erosion Proposals in the light of alternative policy choices which were available to the OECD. These major alternative policy choices include destination-based cash-flow taxation, residual profit allocation by income, formulary apportionment and expanding the concept of permanent establishment. In each case these policies are explained and the advantages and disadvantages of the major policy discussed. Each policy is then analysed to see what it has contributed to the 2020s compromise and what further contribution it might make to international tax reform in the future.What emerges from this analysis is that key elements of the reform owe much to the destination basis of taxation present in the various alternative reform options and selectively adopted in particular by the Unified Approach in Pillar One.
This final chapter looks at the alternatives between unilateral digital services taxes and a multilateral consensus on international tax reform. It analyses the key features of digital services taxes and contrasts the advantages and disadvantages against a multilateral solution. Then it goes on to analyse five key future international tax trends that form part of the 2020s compromise and considers the tax implications in the light of the COVID-19 crisis.
This final chapter looks at the alternatives between unilateral digital services taxes and a multilateral consensus on international tax reform. It analyses the key features of digital services taxes and contrasts the advantages and disadvantages against a multilateral solution. Then it goes on to analyse five key future international tax trends that form part of the 2020s compromise and considers the tax implications in the light of the COVID-19 crisis.
The question of how to tax multinational companies that operate highly digitalised business models is one of the most contested areas of international taxation. The tax paid in the jurisdictions in which these companies operate has not kept pace with their immense growth and the OECD has proposed a new international tax compromise that will allocate taxing rights to market jurisdictions and remove the need to have a physical presence in the taxing jurisdictions in order to sustain taxability. In this work, Craig Elliffe explains the problems with the existing international tax system and its inability to respond to challenges posed by digitalised companies. In addition to looking at how the new international tax rules will work, Elliffe assesses their likely effectiveness and highlights features that are likely to endure in the next waves of international tax reform.
Located on the east coast of Australia, Byron Bay is well recognised as a popular tourism and wellness destination that offers an eclectic mix of ‘alternate’ services and businesses that provide health and wellbeing experiences including alternative ‘new-age’ shops, ‘spiritual’ services such as meditation and yoga classes, alternative medicine and holistic healing centres. This article traces the development of wellness tourism products and experiences in the destination and explores the implicit link to wellness and spiritual values that underpin the local community. This case study research forms part of a Sustainable Tourism Cooperative Research Centre project undertaken in 2009 that investigates the demand and supply of wellness and medical tourism in Australia. A key outcome of this research was to identify factors that have contributed to establishing Byron Bay as an ‘alternate’ wellness tourism destination for domestic and international visitors. In addition, barriers and opportunities for further development in health and well tourism are identified.
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