Michael Wells

PhD Candidate

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Michael is a PhD Candidate at Melbourne Law School. He researches in the field of taxation, in particular corporate and international taxation. His PhD thesis examines the principles, design and implementation of corporate minimum book taxes.

Michael is a tax barrister at the Victorian, New South Wales and Queensland Bars. He holds a Master of Laws from the University of Sydney, Master of Taxation from the University of Sydney and a Master of International Tax from the University of Melbourne.

Thesis Title

Corporate Minimum Book Taxes: Principles, Design and Implementation

Thesis Summary

The principles, design and implementation of corporate minimum book taxes characterised by an effective tax rate of at least 15% on a tax base calculated by reference to financial accounting income of constituent entities of large multinational entities in the context of the recent development of the Organization for Economic Cooperation and Development / Group of 20 ‘Global Anti-Base Erosion Rules’, United States ‘corporate alternative minimum tax’, United Kingdom ‘multinational top-up tax’, European Union Council Directive on ensuring a minimum level of taxation for multinational groups, and other qualified domestic minimum top-up taxes.


  • International Tax
  • Taxation Law