Clayton’s Business Warehousing and Profit Tax

Abstract

Global Warehouses have evolved with the growth of e-commerce. In Australia and around the world, many warehouses with state of the art facilities have been established that makes it possible for foreign entities to do business in Australia without creating physical presence, i.e. a Clayton’s business. This paper explores whether Australia is losing out on collecting the tax revenues from the profits generated by such businesses in Australia. The paper also explores whether the recent changes to the definition of Permanent Establishment in the OECD Model Tax Convention are sufficient to capture the required tax revenues in Australia, or whether a Destination Based Tax would benefit Australia in the long run.