Professor Craig Macfarlane Elliffe

PhD, LLM (hons) Cambridge, LLB (hons), BCom Otago, FCA

Profile Image
Assoc Dean Postgraduate


Professor Craig Elliffe, LLB(Hons), BCom Otago, LLM Camb, PhD Camb, FCA. Craig is a Professor specialising in taxation in the Law Faculty. Craig was appointed to a chair after 14 years as a tax partner at KPMG and 9 years as a tax partner at Chapman Tripp. 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), which was awarded the JF Northey best law book award in 2015, and Dividend Imputation: Practice and Procedure (Lexis) and has written numerous articles and other materials on tax. He is listed in Chambers and the International Tax Review as a leading tax practitioner. He is the Director of the MTaxS programme (the leading postgraduate tax course in New Zealand). He was a member of the Government's Tax Working Group (2018/19).

Craig's latest book is about Taxing the Digital Economy and is published by Cambridge University Press (2021).

Previous roles

Professor of Taxation Law and Policy, University of Auckland, Faculty of Business and Economics (2008- 2015)

Partner Chapman Tripp (2001-2009)

Partner KPMG New Zealand (1989-2001)

Senior Manager KPMG (Auckland) (1987-1989)

Tax Consultant Touche Ross (London) (1986-87)

Solicitor, Russell McVeagh (1984-85)

Part-time Lecturer in international tax at the University of Auckland (2000-2007)

Part-time Lecturer in taxation law at the University of Otago Faculty of Law (2000)

Board Member of KPMG New Zealand (1999-2001)

Board Member Chapman Tripp (2005-2008)

Professional Activities

Consultant to Chapman Tripp, Solicitors, (2009-current)

Member of the Permanent Scientific Committee of the International Fiscal Association (2012-2018)

The International Fiscal Association (IFA) was established in 1938 with its headquarters in the Netherlands. It is the only non-governmental and non-sectoral international organisation dealing with fiscal matters. Its objects are the study and advancement of international and comparative law in regard to public finance, specifically international and comparative fiscal law and the financial and economic aspects of taxation. Craig was the first ever New Zealander appointed to this Committee.

New Zealand Institute of Chartered Accountants National Tax Advisory Group Committee (1/1/2009-current)

CPA Australia New Zealand Tax Advisory Group (1/1/2013-current)

Member of the Tax Avoidance Working Group 2011 (a review of New Zealand's tax avoidance rules)

External Quality Reviewer of the Office of the Chief Tax Counsel (New Zealand Inland Revenue) (2012, 2016 and 2020)

External Quality Reviewer of the New Zealand Inland Revenue (Policy and Strategy) (2013-2015 and 2017-2020)

Research | Current

International tax, tax avoidance and tax reform

For an up to date list of publications please see my SSRN page:

Teaching | Current



  • 2022    LAWCOMM 775    International Taxation (Masters and Honours)
  • 2022    COMLAW 740       The Tax Base (Masters)
  • 2022    LAWCOMM 420    Advanced Tax Law (Stage 4 undergraduate law)


Postgraduate supervision


Dr Victoria Plekhanova (Global Matchmakers: Tax Challenges and Responses in the Digital Economy)- Graduated in 2018

Dr Jeremy Beckham (Strengthening the Settings for Inland Revenue's Statutory Role as Tax Collector)-Graduated in 2018

Alison Pavlovich (International tax)

Matt Andrew (International Tax)

Maria Eleni Pouliasi (International Tax)



  • 2020 Shortlisted Article (one of six in the world) for the Frans Vanistendael award (best article in international tax)
  • 2020 ATTA Patron's Award for Judicial Engagement (best tax article in Australasia which draws attention to members of the Academy and judiciary of a continuing dialogue between the two)
  • 2018 New Zealand Law Foundation’s International Research Fellow, Te Karahipi Rangahau ā Taiao
  • 2017 Faculty of Law Research Excellence Award
  • 2017 Shortlisted Article (one of six in the world) for the Frans Vanistendael award (best article in international tax)
  • 2016 Awarded JF Northey Prize by the Legal Research Foundation for best legal book published in New Zealand for International and Cross-Border Taxation in New Zealand, Thomson Reuters (2015)
  • 2011 Teaching Excellence Awards - Master of Taxation Studies Tax Teaching Team
  • 2012 Faculty of Business Research Excellence Awards-Research Relevance


Associate Dean Postgraduate

Director of the Master of Taxation Studies

Co-Director of the Centre for Law and Business

Director of Professional Programmes and Relations

Areas of expertise

International Tax, Corporate Tax, Tax Reform (taxes on capital income), and Tax Avoidance

Committees/Professional groups/Services

Member of the Permanent Scientific Committee of the International Fiscal Association (2012-2018)

Deputy Chair of the Chartered Accountants Australia and New Zealand Tax Advisory Group


Selected publications and creative works (Research Outputs)

As of 29 October 2020 there will be no automatic updating of 'selected publications and creative works' from Research Outputs. Please continue to keep your Research Outputs profile up to date.
  • Elliffe, C. (2019). The meaning of the principal purpose test: One ring to bind them all?. World Tax Journal, 11 (1), 47-76. Related URL.
  • Elliffe, C. M. (2018). International and Cross-Border Taxation in New Zealand (2nd). Wellington: Thomson Reuters.
  • Elliffe, C. (2018). Interpreting international tax agreements: Alsatia in New Zealand?. New Zealand Universities Law Review, 28 (1), 1-24. Related URL.
  • Elliffe, C. M., Peters, C., & Vial, P. (2017). New Zealand Branch Report. Assessing BEPS: origins, standards, and responses (pp. 571-596). The Hague, Netherlands: International Fiscal Association. Related URL.
  • Elliffe, C. (2017). International aspects of capital gains taxation. In M. Littlewood, C. Elliffe (Eds.) Capital gains taxation: a comparative analysis of key issues (pp. 81-112). Cheltenham Glos: Edward Elgar Publishing. 10.4337/9781784716028.00011
  • Littlewood, M., & Elliffe, C. (Eds.) (2017). Capital gains taxation: A comparative analysis of key issues. Cheltenham, UK: Edward Elgar Publishing. Pages: 411. 10.4337/9781784716028
    Other University of Auckland co-authors: Michael Littlewood
  • Elliffe, C. (2017). Interest deductibility: Evaluating the advantage of earnings stripping regimes in preventing thin capitalisation. New Zealand Law Review, 2017 (2), 257-284.
  • Elliffe, C. (2017). New Zealand: Treaty interpretation on an exchange of information. In E. C. Kemmeren, D. S. Smit, P. Essers, M. Lang, J. Owens, P. Pistone, A. Rust, J. Schuch, C. Staringer, A. Storck (Eds.) Tax treaty case law around the globe 2016 (pp. 3-20). Vienna, Austria: Linde.

Contact details

Primary office location

9 EDEN CRESCENT - Bldg 801
Level 4, Room 419
New Zealand

Web links