Australia’s Multinational Anti-Avoidance Law (2016): Treating the Symptom Rather than the Disease

Abstract

In July 2017, it was reported that funds held by US non-financial multinational enterprises (MNEs), from non-US income, was US$1.84 trillion at the end of 2016. Provided the income is not remitted to the US, under the US Tax Code prior to the December 2017 amendments, these non-US earnings of US multinationals are shielded from US taxation. The top five cash-rich US companies according to the report are the bedrock of the world’s digital economy: Apple, Microsoft, Google, Cisco and Oracle. In this group, Google is the biggest media entity in the world and reported in 2016 that its revenue from advertising was US$79.4 billion. Google advertising can reach an audience of millions of in..