The taxation of multinational banking income : is the traditional rationale correct?

Sadiq, Kerrie (2008) The taxation of multinational banking income : is the traditional rationale correct? Journal of Banking and Finance Law and Practice, 19(4), pp. 229-248.

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Abstract

This article argues that multinational banks have characteristics which are unique and distinguishable from traditional multinational entities. The first distinguishing feature is the unique nature of the services and consequent products supplied by multinational banks, which are aimed at meeting client global demand. The second distinguishing feature is the non-traditional organisational structure that is adopted. This structure, also designed to meet client global demand, introduces issues previously not recognised in the traditional taxation system, which is designed for the structure of traditional multinational entities. The unique differences between traditional multinational entities and multinational banks means there may be the need for a distinct international tax regime. It is argued that there are “outmoded economic assumptions” upon which the present tax laws relating to multinational banks are based. An examination of the unique nature of multinational banks leads to the conclusion that the appropriate tax treatment of these banks is different from the appropriate tax treatment of multinational entities generally.

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ID Code: 49822
Item Type: Journal Article
Keywords: multinational banking income, appropriate tax, economic assumptions
ISSN: 1034-3040
Subjects: Australian and New Zealand Standard Research Classification > COMMERCE MANAGEMENT TOURISM AND SERVICES (150000) > ACCOUNTING AUDITING AND ACCOUNTABILITY (150100) > Accounting Auditing and Accountability not elsewhere classified (150199)
Divisions: Current > QUT Faculties and Divisions > QUT Business School
Current > Schools > School of Accountancy
Copyright Owner: Copyright 2008 Lawbook Co.
Deposited On: 24 Apr 2012 02:10
Last Modified: 08 Jul 2012 05:12

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