Making a Case for Increased Judicial Globalization in Consumption Tax Law
Bibliographic record
Abstract
This article makes a case for increased judicial globalization in consumption tax law. The author argues that judicial globalization will assume increased importance once the Organisation for Economic Co-operation and Development (OECD) has released its final International vat/gst Guidelines. It is expected that the guidelines will be adopted worldwide, and will thus have the effect of further homogenizing consumption tax principles around the world. As a result, global judicial dialogue in this field will be increasingly relevant, beneficial, and necessary. The article sets out to demonstrate, on the one hand, the advantages of having courts around the world engage in a global judicial dialogue in the field of consumption tax law, and, on the other hand, the disadvantages of not engaging in this type of dialogue. To achieve this, the author analyzes the judicial dialogue, or lack thereof, between courts in Canada and Europe. The focus is on judicial dialogue over a heavily litigated legal question: When a transaction consists of more than one supply, how should the courts determine whether all the supplies should be treated as parts of a single taxable supply, or whether each supply should be taxed separately? This question can be of significance to taxpayers, consumers, and domestic tax authorities, and it is specifically addressed by the OECD in the International vat/gst Guidelines. Through a comparative analysis of cases that have dealt with the single supply question, the author shows the value of engaging in a global judicial dialogue in the field of consumption tax, and concludes that a shift in the attitude of the courts toward engaging in such dialogue should begin sooner rather than later. In this regard, credit must be given to the Canadian courts for their leadership in this emerging global trend.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.026 | 0.029 |
| Meta-epidemiology (narrow) | 0.000 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.012 | 0.034 |
| Scholarly communication | 0.016 | 0.021 |
| Open science | 0.002 | 0.014 |
| Research integrity | 0.017 | 0.022 |
| Insufficient payload (model declined to judge) | 0.005 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".