BOOK LAUNCH: International Taxation of Trust Income: Principles, Planning and Design

27 August 2019



BOOK LAUNCH: International Taxation of Trust Income: Principles, Planning and Design

Author: Mark Brabazon SC, 7 Wentworth Selborne Chambers

Professor Richard Vann, Sydney Law School, will launch the book.

In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty.

About the author

Mark Brabazon SC

Mark Brabazon took silk in 2008. He acts for private and government clients in tax, equity and commercial cases, in public and administrative law, and in general appeals. His practice covers all stages from planning, advice and investigation through ADR and trial litigation to final appeal. He is the author of 'The Application of Tax Treaties to Fiscally Transparent Entities' in the Global Tax Treaty Commentaries (IBFD online, 2018), and his doctoral thesis on the international taxation of trust income is to be published by Cambridge University Press.

Mark is the chair of the Council of Law Reporting for New South Wales. His professional and academic writings have been published in journals including the Australian Law Journal, British Tax Review, Australian Tax Forum, Australian Tax Review, New Zealand Journal of Tax Law and Policy, Australian Bar Review and Australian GST Journal.

Mark is also the chair of the Costs and Fees Committee of the New South Wales Bar Association, and is recognised as an expert on the law relating to legal costs.

Information about the book

This book launch is sponsored by the Ross Parsons Centre of commercial, corporate and taxation research at Sydney Law School.


Time: 6-8pm (cocktail reception and book launch)

Location: Common Room, Level 4, New Law Building (F10), Eastern Avenue, Camperdown, University of Sydney

Cost: Complimentary, however registration is essential.

Contact: Professional Learning & Community Engagement

Phone: 02 9351 0429

Email: 1c374174574f005c1537225c5600040e34403f103164373c