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The theoretical foundations and continued rationale for source-based taxation in an electronic commerce environment

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Published on 01 Aug 12 by "AUSTRALIAN TAX FORUM" JOURNAL ARTICLE

This paper is directed at analysing the theoretical foundations and rationale for source-based taxation and argues that these principles remain valid despite changes brought about by globalisation, including the increased incidence of transactions that occur via electronic commerce.

The analysis in this paper is not concerned with how source is defined, but rather at establishing that source-based taxation continues to be theoretically justifiable for income that arises from international transactions which are conducted in a globalised business environment, including those that occur through the agency of electronic commerce.

Author profile

Prof Dale Pinto CTA-Life
Photo of author, Dale PINTO Dale is currently Professor of Taxation Law in the Curtin Law School as well as being the Chair of the Academic Board at Curtin University. Dale is the author and co-author of numerous books, refereed articles and national and international conference papers and sits on the editorial board of a number of peer-reviewed journals as well as being the Editor-in-Chief of several refereed journals. He is a member of the Board of CPA Australia and is also a Fellow of the Australian Academy of Law as well as being a Chartered Accountant, Chartered Tax Adviser and Honorary Life Member of the Tax Institute. He is also a Life Member of the Australasian Tax Teachers Association and the Australasian Law Teachers Association. Dale has been a registered tax agent for more than 25 years and was appointed by the Assistant Treasurer as one of the inaugural members of the National Tax Practitioners Board. He is a current member of the Board of Taxation’s Special Advisory Panel and the ATO’s Tax Technical Panel as well as the Chamber of Commerce and Industry’s Economic Development Forum in WA. Dale is a member of the Tertiary Education and Quality Standards Agency (TEQSA) Expert Panel in Accounting, Taxation and International Education. - Current at 13 August 2019
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