The obvious commercial benefits of centralising operational functions mean that commercial ‘hubs’ within multinational enterprises will continue to proliferate. More and more so, this will create challenges for the revenue authorities of the high tax jurisdictions such as Australia and the United States, and also the ‘hub-destination’ jurisdictions such as Singapore. For the Australian revenue authority, the challenges are heightened by the fact that the Australian public debate on these issues occurs, it seems, within a framework of suspicion that multinational enterprises set about to avoid paying their ‘fair share’ of tax. As there is ultimately only one value chain spread across more than one tax jurisdiction – whether that be from the hydrocarbons under an Australian sea bed through to a customer sale in North Asia, or the purchase of crude in Singapore through to a point of retail distribution in Australia – it is essential that the tax laws arrive at an international organising principle that fairly allocates taxing rights between the tax jurisdictions affected by a global value chain. Double taxation will arise and economic efficiencies will be destroyed if multiple tax jurisdictions seek to tax the same parts of the single global value chain. That organising principle should be the ‘arm’s length principle’, the fundamental basis upon which Australia enters into double tax treaties with its trading partners. This paper analyses the manner in which the Australian tax laws attempt to deal with the advent of offshore centralised hubs. It argues that the Australian tax laws overreach and, as such, create an environment for double taxation and dispute between competing revenue authorities and between revenue authorities and multinational enterprises. The tax laws are complex, incomplete and, at the time of writing, evolving at a speed not often witnessed in the field of taxation.