Number 3 - 2007 contains the following:
 

This article discusses the cross-border aspects of pensions, focusing on the connection between the treatment of pension schemes under tax treaties and the treatment under EU law. The cross-border aspects of pensions are characterized primarily by the potential conflict between two factors: the ability to accrue a pension without impediments during the accrual phase, and the claim which the legislature wants to maintain to the fullest extent possible on the payments made from pensions accrued under favourable tax provisions. It is not easy to balance these two factors, if only because tax treaties and EU law both apply and, for the time being, the national legislatures appear to have little grip on the situation. The discussion considers the international and EU tax aspects, with particular emphasis on the Dutch perspective.

This article examines the impact of Art. 27 (Non-discrimination) of the Nordic convention on the tax treatment of cross-border economic relations between nationals or residents of two different Nordic countries. The article also discusses the relevant requirements of the EC Treaty and the EEA Agreement.

This article traces the development of the British provisions through the drafts and laws of the income tax in Australia and New Zealand and the ultimate emergence of the Australasian GAAR. These developments are traced through four time periods. The first period - from the Tasmanian draft income tax of 1866 to the New Zealand property tax of 1879 - is the most important because it set the foundations of the GAAR. The second period saw the start of income taxation in the Australasian colonies and thus the jumping of the GAAR from the land and property taxes to the income tax. The third period identified the New South Wales draft law of 1893 as the most direct origin of the wording used in the Australasian GAAR, and that influence found its way to the New Zealand income tax. In the final period, which started with the first consolidation of the New Zealand income tax in 1900, the development of the GAAR can be traced through the adoption in the Australian income tax of 1915 and its subsequent consolidation.