Research Papers

International Tax Policy & BEPS

1. An Assessment of the Potential Economic Impact of BEPS Project Action 4 on Companies in Asia — Published in the Bulletin for International Taxation

2. The Convergence and Divergence between China's Implementation and OECD/G20 BEPS Minimum Standards — Published in the World Tax Journal

3. International Tax Law in the Post-BEPS World — Dr Christiana Panayi, Professor in Tax Law, Queen Mary University of London

4. Tax Treaty Policy of Developing Countries post-BEPS — Dr Graeme Cooper, Professor of Taxation Law, University of Sydney

5. Objective or Subjective — Anti-Treaty Shopping Policy in Selected Asian Jurisdictions in the Post-BEPS World — Mr Andy Baik, Principal, Ernst & Young LLP & Dr Matthias Petutschnig, Associate Professor, Vienna University of Economics and Business

Permanent Establishment

1. Necessity of the Dependent Agent Permanent Establishment — Ms Yong Sing Yuan, Tax Director, IRAS & Mr Tommy Yee, Senior Lecturer, SUSS

2. Impact of OECD BEPS Action 7 Proposals on Modification of Articles 5(4), 5(5) and 5(6) of OECD Model Convention — Mr Tan Ching Khee, Partner, EY Solutions LLP & Mr Henry Syrett, Partner, EY Solutions LLP

Anti-Avoidance & Treaty Abuse

1. The Principal Purposes Test (PPT) in BEPS Action 6/MLI: Exploring Challenges arising from its Legal Implementation and Practical Application — Dr Blazej Kuzniacki, SMU-TA Centre for Excellence in Taxation. Published in World Tax Journal 2018, Issue 2

2. Discretionary Benefits Provisions Under the MLI: A Virtuous Solution or a Vicious Circle? — Dr Blazej Kuzniacki, SMU-TA Centre for Excellence in Taxation. Published in Tax Notes International, July 31, 2017

3. Mismatches in Tax Outcomes in the Light of BEPS Actions 2 & 5 — Mr Lukas Mechtler, Vienna University of Economics and Business & Ms Cindy Wong, Group Tax Specialist, IRAS

4. Developing an Artificial Intelligence Tax Assistant in International Tax Avoidance Cases: The Case Study under the PPT — Dr Blazej Kuzniacki, SMU-TA Centre for Excellence in Taxation

5. Countering Treaty Abuse Using Singapore's General Anti-Abuse Rule and the Principal Purpose Test — Mr Tay Ang Sim, Group Tax Specialist, IRAS

Tax Treaties & Double Taxation

1. The Impact of Double Tax Treaties on Inward FDI in ASEAN Countries — Dr Dong Yue, SMU-TA Centre for Excellence in Taxation. Published in the Journal of Business and Finance in Emerging Markets

2. The Need for a New Australia-Singapore Tax Treaty — Prof John Taylor, University of New South Wales

3. Taxpayers' Right of Defence in the International Context: the Case of Exchange of Tax Information and a Proposal for the "English" Wednesbury Doctrine as the New OECD (BEPS) Standard — Published in the World Tax Journal

4. Critical Evaluation of Action 14 – Recommendations and the Suggested Way Forward for Singapore — Mr Luis Coronado & Mr Jerome van Staden, Ernst & Young Solutions LLP

Transfer Pricing & Intangibles

1. Related Parties as used in Transfer Pricing — Ms Yong Sing Yuan, Tax Director, IRAS & Ms Jow Lee Ying, Senior Lecturer, Nanyang Technological University. Published in IBFD

2. Taxation and Pricing of Intangibles — Mr Alan Ross, former Tax Practice Leader, PwC Singapore

Corporate Tax & Tax Incentives

1. Common Consolidated Corporate Tax Base and Limitation on Benefits Clauses — Dr Matthias Petutschnig, Assistant Professor, Vienna University of Economics and Business

2. Reviewing the OECD's and the EU's Assessment of Singapore's Development and Expansion Incentive — Dr Frederik Boulogne, Tax Lawyer at Lubbers, Boer & Douma and Researcher at VU University Amsterdam

3. Local Tax Incentives and Behaviour of Foreign Enterprises: Evidence from a Large Developing Country — Prof Jing Xing, Shanghai Jiao Tong University; Prof Wei Cui, University of British Columbia; Prof Xi Qu, Shanghai Jiao Tong University

4. Territorial Tax System Reform and Multinationals' Foreign Cash Holdings: New Evidence from Japan — Dr Jing Xing, Shanghai Jiao Tong University; Dr Stephen Bond & Dr Giorgia Maffini, University of Oxford. Published in the Journal of Corporate Finance

5. Is Accounting Profits Still an Appropriate Basis for Income Taxation? — Ms Cindy Wong, Tax Director, IRAS

Digital Economy & Tax

1. Tax Challenges in Debt Financing involving Digital Tokens — Mr Vincent Ooi, Lecturer, Yong Pung How School of Law, Singapore Management University

Indirect Tax (GST/VAT)

1. International Trade in B2B Services under VAT/GST Law and the Role of Permanent/Fixed Establishments: A Comparison of EU VAT and Singaporean GST in the Light of the OECD VAT/GST Guidelines — Published in Asia-Pacific Tax Bulletin 25:3 (2019)

Tax Transparency & Information Exchange

1. What is the Cost of Transparency? Does it Outweigh the Benefits Obtained from Greater Transparency? — Ms Viktoria Wohrer, PhD candidate, Vienna University of Economics and Business

2. Current Trends on Automatic Exchange of Information — Dr Christiana Panayi, Professor in Tax Law, Queen Mary University of London

Tax Dispute Resolution

1. A Step Forward for Tax Dispute Resolution between China and ASEAN Countries under the Belt and Road Initiative — Dr Xu Diheng, SMU-TA Centre for Excellence in Taxation

Tax Competition & Capital Flows

1. International Tax Competition, Capital Mobility, and Inequality: Empirical Evidence from Asia-Pacific Economies — Dr Xu Chengwei, SMU-TA Centre for Excellence in Taxation & Ms Yeh Chin Feng, Principal Tax Specialist, IRAS

2. Singapore and the One Belt One Road Initiative: Potential Tax Implications for Investors in the Land Route — Dr Jasmin Kollmann, EY Munich

Tax Governance

1. The Globalisation of Tax Good Governance — Dr Christiana Panayi, Professor in Tax Law, Queen Mary University of London