You are here: Home / Sydney Law School / About us / Our people / Academics

Professor Rebecca Millar

Profile

Degrees
BSc (Zoology) Auck LLB NSW LLM Syd

Courses

  • Goods and Services Tax Principles
  • Advanced GST
  • Comparative Value Added Tax
  • Tax Incentives
  • Personal Taxation
  • Business Taxation
  • Foundations of Law


Brief Biographical Details

Rebecca is a Professor at the Faculty of Law at the University of Sydney. In 2005, Rebecca took leave from the University to take up a 6 month position as a consulting counsel in taxation for the Legal Department of the International Monetary Fund (IMF). Since then, she has continued to be engaged on a part time basis, both by the IMF and the World Bank, to provide technical assistance and training on indirect tax laws. Through this work, she has provided technical assistance to a number of countries introducing new value added tax and excise tax regimes.

Her areas of interest include GST, comparative VAT, and tax in development. Since 2007, Rebecca has been a pro bono academic advisor to the secretariat of the OECD's Working Party No 9 (WP9), assisting the secretariat in its work with the Technical Advisory Group (TAG) advising WP9 on the development of International VAT/GST Guidelines.

Rebecca was a member of the panels of experts appointed by the Board of Taxation to assist it with technical and practical advice on the key issues and recommendations and the technical content of its Review of the Legal Framework for the Administration of the GST (2009) and its Review of the Application of GST to Cross-Border Transactions (2010). Between 2003 and 2008, she was also engaged by the Australian Taxation Office to participate as a member of its GST (later Indirect Taxes) Rulings Panel.

Before joining the University of Sydney, Rebecca worked as a tax practitioner for 10 years, initially with Michael Johnson & Associates, a firm specialising in Government support programs for research and innovation and then as a GST advisor with the accounting firm Ernst & Young. She continues to work with Michael Johnson & Associates on an occasional basis on issues relating to tax concessions for R&D.

Publications

Chapters in Books | Articles in Refereed Journals | Other Articles | Conference Papers and Presentations | Research grants


Chapters in Books

  • Millar, R, ‘Smoke and Mirrors: applying the full taxation model to government under the Australian and New Zealand GST laws’ in Rita de la Feria (ed), VAT Exemptions: Consequences and Alternatives, Kluwer Law: The Hague (2013) 135-174
  • Millar, R, ‘VAT and immoveable property: full taxation models and the treatment of capital gains on owner-occupied residences’ in Rita de la Feria (ed), VAT Exemptions: Consequences and Alternatives, Kluwer Law: The Hague (2013) 254-305
  • Millar, R and McCarthy, D, ‘Australia’ in Thomas Ecker, Michael Lang, and Ine Lejeune (eds), The Future of Indirect Taxation: Recent Trends in VAT and GST Systems Around the World, Kluwer Law International: The Netherlands (2012) 21-96; available as Sydney Law School Research Paper No. 12/40
  • Millar, R ‘The destination principle: past developments and future challenges’ in Christine Peacock (ed), GST in Australia: Looking forward from the First Decade, Thomson Reuters: Australia (2011) 313-341; available as Sydney Law School Research Paper No. 12/33
  • Millar, R ‘Echoes of Source and Residence in VAT Jurisdictional Rules’ in Lang, Melz and Kristoffersson (eds), Value Added Tax and Direct Taxation – Similarities and Differences, IBFD: Amsterdam, the Netherlands (2009) 275-321; available as Sydney Law School Research Paper No. 09/44
  • Millar, R ‘Intentional and Unintentional Double Non-taxation’ in Lang, Melz and Kristoffersson (eds), Value Added Tax and Direct Taxation – Similarities and Differences, IBFD: Amsterdam, the Netherlands (2009) 409-442; available as ‘Intentional and Unintentional Double Non-taxation Issues in VAT’ Sydney Law School Research Paper No. 09/45
  • Millar, R, 'Jurisdictional Reach of VAT’ in R Krever (ed) VAT in Africa Pretoria University Law Press (PULP) (2008) 175 - 214; available as Sydney Law School Research Paper No. 08/64
  • Millar, R, 'Cross Border Services - A Survey of the Issues' in R Krever & D White (eds) GST in Retrospect and Prospect, Brookers Ltd: New Zealand (2007) 317-348

Articles in Refereed Journals

  • Millar, R, "What's VAT got to do with it?" (2012) 12 Australian GST Journal 99-124
  • Parolini, A, Bechara, C, van Hilten, M, Kruger, D, Millar, R and Sinfield, G, 'VAT and group companies' (2011) 65(6) Bulletin for International Taxation 349-362
  • Millar, R, ‘Taxing the Bull by the Horns: Reforming Australia's Cross-Border GST Rules’ (2009) 24(3) Australian Tax Forum 281-340; available as Sydney Law School Research Paper No. 09/80
  • Millar, R, ‘Cross Border Services – A Survey of the Issues’ (with postscript) (2007) Vol 13:2 New Zealand Journal of Taxation Law and Policy 302-328; updated as ‘Sources of Conflict in Cross-Border Services Rules for VAT’ Sydney Law School Research Paper No. 08/14
  • Millar, R, 'GST Issues for international services transactions' (2004) 4 Australian GST Journal 285-308
  • Millar, R, 'Marana Holdings' (2004) 4 Australian GST Journal 311-314. Also published as: 'GST: Residential premises: Delineating the boundaries of input taxed treatment - the decision in Marana Holdings' (2004) 50 Weekly Tax Bulletin [2130] at pp. 2011-2017
  • Millar, R, 'Time is of the essence: supplies, grouping schemes, and cancelled transactions' (2004) 7(2) Journal of Australian Taxation 132 -195; available as Sydney Law School Research Paper No. 07/83
  • Millar, R, 'Constitutional validity of Australian GST upheld' (2003) 14(3) International VAT Monitor 257-259 (Case Note)
  • Millar, R, 'Illusory Supplies and Unacknowledged Discounts: VAT and Valuation in Consumer Transactions' (2003) British Tax Review 153-184
  • Millar, R, 'The Australian GST treatment of telephone cards' (2003) 14(5) International VAT Monitor 365-372
  • Millar, R, 'The Vouchers Problem: an insoluble conflict or an illustration of the nature of consideration in the "complex parallel universe" of GST?' (2003) 18 Australian Tax Forum 107-170
    Reproduced in two parts by Thomson ATP in the Australian GST Journal as:
    - 'The Vouchers Problem: Part I' (2003) 3 Australian GST Journal 61-71
    - 'The Vouchers Problem: Part II' (2003) 3 Australian GST Journal 91-107
  • Millar, R, Commentary on the research and development tax concession, ss 73B-73Z of the Income Tax Assessment Act 1936, Australian Federal Tax Reporter, (CCH Looseleaf Service, 1993-2003), published in hard copy, on line & CD

Other Articles

  • Millar, R, 'Is VAT Relevant for U.S. Businesses?' (2012) 66(12) Tax Notes International 1140-1142
  • Millar, R, 'Brady King: Reliance Carpet Bites Back' (2008) GST News Issue 7 (23 July 2008) ¶49; reproduced in CCH Tax Week Issue 29 (24 July 2008) ¶653
  • Millar, R, 'Is a motel residential premises? An alternative view of Marana Holdings' (2004) 226 GST News Alert [1]
  • Millar, R, ' Impact of GST 2003/5' (2003) 3 Australian GST Journal 90-91
  • Millar, R, 'Final GST Ruling on vouchers' (2003) 6 GST News 1-4; reproduced in (2003) 27 CCH Tax Week 469
  • Millar, R, 'Adjustments for cancelled travel: an alternative view' CCH Tax Week, Issue 45(22Nov2001); reproduced in The GST Newsletter, CCH, Issue 9 (19Nov2001)
  • Millar, R, 'Draft GST ruling on vouchers - taxing the same transaction twice' CCH Tax Week, Issue 48, (1Dec2000); reproduced in The GST Newsletter, CCH, Issue 22, (27Dec2000)
  • Millar, R, 'Another nail in the coffin of the R&D concession' CCH Tax Week, Issue 1 (6 January 2000)
  • Millar, R, 'R&D: the meaning of purpose' CCH Tax Week, Issue 30 (16 July 1999)
  • Millar, R, 'R&D Tax Concessions: Year End Update' (1996) 8(2) CCH Journal of Taxation
  • Millar, R, 'R&D Tax Incentive' (1995) 7(5) CCH Journal of Taxation
  • Millar, R, 'Eliminating the Uncertainty - Overseas R&D' (1995) Taxation in Australia
  • Millar, R, 'Further Developments in R&D: the Charles IFE Decision' CCH Tax Week, Issue 39 (8Sept 1995)

Conference Papers and Presentations

  • Millar, R, 'Cross-border VAT and intra-entity "transfers" by multiple location entities', at EU Tax Policy Conference, Institute for Public Finance and Tax Law (IDEFF), Law Faculty of the University of Lisbon, Portugal, 6-8 June 2012
  • Millar, R, 'What’s VAT got to do with it?' at National GST Symposium 2012: Putting the purpose in ‘creditable purpose’, Melbourne Law School, 1 May 2012
  • Millar, R and Moon, L, 'Australia', at Improving VAT and GST – Designing a simple and fraud-proof tax system, Vienna University of Economics and Business, Vienna, Austria, 29 February-2 March 2012
  • Millar, R, 'The destination principles: future directions a challenges', at GST in Australia: Looking forward from the First Decade, RMIT, Melbourne, 17-18 November 2010
  • Millar, R and McCarthy, D, 'Australia', at Global VAT/GST conference: The future of indirect taxation: recent trends in VAT and GST systems around the world a global comparison, organized by PricewaterhouseCoopers and the Institute for Austrian and International Tax Law, Vienna University of Economics and Business, Rust, Austria, 9-11 September 2010
  • Millar R, 'VAT treatment of immoveable property' at VAT Exemptions: consequences and Design Alternative, joint conference of the Centre for Business Taxation, Oxford University and Fiscal Institute Tilburg, Tilburg University, Worcester College, Oxford, 15-16 April 2010
  • Parolini, A, Bechara, C, Van Hilten, M, Kruger, D, Millar R and Sinfield, G, ‘Seminar D: VAT/GST and group companies’, at Annual Congress of the International Fiscal Association, Rome, 2010
  • Millar, R, ‘Australia’s Cross-Border Rules: Taxing the Bull by the Horns’, at the 21st Annual GST and Indirect Tax Weekend Workshop, ATAX, University of New South Wales, Noosa, 16-18 April 2009
  • Millar, R, ‘Intentional and Unintentional Double Non-Taxation’, at Value Added Tax and Direct Taxation – Similarities and Differences, International Network for Tax Research Conference at Vienna University of Economics and Business, organised by the Institute for Austrian and International Tax Law, Vienna University of Economics and Busines and the Institute for VAT Research at Stockholm University, 26-28 March 2009
  • Wildeboer, H, Bill, S, Cisterna, D, Grousset, A, Millar, R and Rumo, G, ‘Seminar B: Physical Presence and Equivalent Concepts for VAT Purposes’, Annual Congress of the International Fiscal Association, Vancouver, 2009
  • Millar, R, ‘The Impact of GST and VAT on Cross-Border Transactions’, presented at Commercial Practice in a Global Economy, a conference organised jointly by the Commercial Law Association of Australia and the Ross Parsons Centre of Corporate, Commercial and Taxation Law, University of Sydney, 1 August 2008
  • Millar, R, ‘Jurisdictional Reach of VAT’, presented to the VAT in Africa Conference, University of Pretoria, 15 June 2007
  • Millar R, “Cross-border services: Everyday issues?” presented at the Taxation Institute of Australia National GST Intensive entitled Taking the reins on GST, Melbourne, November 2006
  • Millar, R, ' Cross-Border Services: A Survey of the Issues', presented at the Twenty Years of GST: The Best Path Forward Conference, Wellington, New Zealand, 16-18 November 2006
  • Van der Paardt, R, Bouchard, J, Diemer, R, Haddad, R, Millar, R, 'Seminar A: Indirect Tax Aspects of Cross-Border Services' Annual Congress of the International Fiscal Association, Amsterdam, 2006
  • Millar, R, 'GST Issues for International Services Transactions', presented at the Australasian Tax Teachers Association Annual Conference, Victoria University of Wellington, New Zealand, January 2005
  • Millar, R, 'International Global Services', presented at the Taxation Institute of Australia National GST Intensive, Coogee, 22-23 October 2004
  • Millar, R, 'Timing, Groups, & the Applicability of UK VAT Avoidance Cases in Australia', presented at the ATAX 16th Annual GST Conference, Noosa, April 2004
  • Millar, R, 'Time, Value, and the Attribution of GST: The effect of time on value when vouchers are redeemed', presented at the Australasian Tax Teachers Association Annual Conference, University of Wollongong, January 2003
  • Millar, R, 'Fuzzy Logic and Foreign Concepts Part II', a presentation on recent UK VAT cases on non-monetary consideration, ATAX 14th Annual GST Conference, Noosa, April 2002
  • Millar, R, 'GST-free Exports of Services', presented at the ATAX 13th Annual GST Conference, Noosa, April 2001
  • Millar, R, 'GST and International Transactions', Taxation Institute of Australia Blue Series Seminars, Menzies Hotel, Sydney, 4 September 2001
  • Rebecca Millar has also presented a number of Conferences on developments in the R&D Tax Concession, including the IBC Congress (March 1999), Victorian CPA Congress (1998), IBC Conference (March 1998), and AIC Conference (April 1996)

Research Grants

  • ARC “GST and the Global Economy: Identifying the underlying causes of consumption tax conflicts affecting cross-border trade” (2006-2008)
  • Sesqui NSSS Grant, “GST and Retirement Villages” (2004)
  • Legal Scholarship Support Fund, "Securities transactions and the use of the financial supply exemption to avoid consumption taxes" (2003)
  • Legal Scholarship Support Fund, "GST on Vouchers, Coupons, and Similar articles: Identifying solutions to the problems of over and under taxation" (2002)