Taxation based on nationality can be problematic under provisions preventing discrimination in domestic law, but particularly when the foreign citizen belongs to a country that has concluded a double tax agreement containing a non-discrimination article. Article 24 of the OECD Model is often overlooked by politicians and can become very inconvenient to policymakers looking for revenue or wanting to influence behaviour. Furthermore, while Article 24 brings a very focused discussion on the treaty-based non-discrimination principle to the debate, advisers should also consider the broader framework of domestic law, which might prevent discrimination on the grounds of nationality.
This seminar examines the unusual scope and application of the non-discrimination provisions, particularly relating to discrimination on the grounds of nationality and mainly focusing on the experience of four Anglo-legal system countries, namely Australia, Canada, New Zealand, and Singapore, where there are both current and potential problems.
SPEAKER
Professor Craig Elliffe
Professor of Tax Law
University of Auckland
Craig Elliffe is a Professor specialising in taxation in the Law Faculty at the University of Auckland, Waipapa Taumata Rau. Craig was appointed to a chair in 2008 after 14 years as a tax partner at KPMG, and 9 years as a tax partner at Chapman Tripp (a major New Zealand law firm). Craig’s research areas are in the field of international tax, corporate tax and tax avoidance. He is the author of “International and Cross-Border Taxation in New Zealand” (Thomson Reuters and now in its third edition), and “Dividend Imputation: Practice and Procedure” (Lexis) and has written numerous articles and other materials on tax. Craig is the Director of the MTaxS programme (the leading postgraduate tax course in New Zealand) and a member of the Government's Tax Working Group in 2018/19. Craig's latest book is about “Taxing the Digital Economy” and is published by Cambridge University Press (2021). He also edited the book "International Tax at the Crossroads", published by Edward Elgar in 2023.
CHAIR
Dr Vincent Ooi
Assistant Professor of Law
Singapore Management University
DETAILS
Date: 01 December 2025, Monday
Time: 4:30pm to 5:30pm [Registration commences from 4.15pm and Light Refreshments will be provided]
Venue: Meeting Room 5-01, Level 5, Yong Pung How School of Law, Singapore Management University
REGISTRATION
Public: SGD54.50 per pax inclusive of 9% GST (non-refundable)
SMU Faculty or Students: Complimentary
Registration closes on 24 November 2025, 5pm SGT or when the workshop is fully subscribed, whichever is earlier.
CO-ORGANISED WITH
The New Zealand Centre for Taxation (NZCT) is Aotearoa’s | New Zealand’s first centre focused on taxation research and scholarship. It is a joint enterprise with the Department of Commercial Law and will be situated in Auckland Law School. The NZCT primarily aims to facilitate interdisciplinary research that focuses on the interaction between taxation law and business, as well as between taxation law and society, the economy, and the political environment.
The Centre is dedicated to fostering and strengthening connections with the local legal, accountancy and business community, and tax policy makers, as well as collaborating with other tax research centres and tax scholars in New Zealand and overseas.
The NZCT also seeks to promote teaching and research which falls within the remit of the Centre. This includes both the business law elements of the Master of Laws (LLM) and its associated programme, the Master of Legal Studies (MLS). Another important area of law is studied in the Master of Taxation Studies (MTaxS) programme, which is designed for both law and commerce graduates who intend to make tax advocacy or tax consulting their career and who wish to extend their understanding of the theoretical issues and legal structures that underpin the taxation system. The centre also aims to establish and promote publications in the field of law and business.
https://www.auckland.ac.nz/en/law/our-research/research-centres/taxation.html
ORGANISERS
About Singapore Tax Academy Research Initiative (STARI)
The Singapore Tax Academy Research Initiative (STARI) conducts leading tax law research in a rapidly developing international tax landscape, while also building domestic tax research capacity, developing strong academic networks, and bringing the best in international tax thought-leadership to the tax profession in Singapore. In addition to its research activities, STARI provides training in academic research and writing, and works with the world’s best tax law academics to develop tax professionals.
https://ccla.smu.edu.sg/stari
About Tax Academy of Singapore
The Tax Academy of Singapore is a not-for-profit institution set up by the Inland Revenue Authority of Singapore in collaboration with the international accounting firms – Deloitte & Touche, Ernst & Young, KPMG and PricewaterhouseCoopers, the Singapore Chartered Tax Professionals, the Institute of Singapore Chartered Accountants and the Law Society of Singapore.
As a leading hub for tax excellence and a network of networks, Tax Academy collaborates with leaders in the industry, academia and the government to develop and deliver structured tax training programmes, regular seminars and conferences. Through these platforms, tax professionals can stay current with global developments while enhancing their professional competency, knowledge and capabilities. By fostering exchanges between industry experts, academics and government officials from both local and international spheres, Tax Academy cultivates an environment of continuous learning and knowledge sharing.
https://www.taxacademy.sg
