He called on regulators to stop online companies such as Uber and Airbnb from dodging their tax obligations.

"It is neither efficient nor equitable to let revenue fall into some dead zone between countries," he said in a speech to the McKell Institute in Sydney.

"One way to address this would be to establish international consensus on the corporate tax base, and then allow countries to compete on the rate."

Apple's Australian entity describes itself as a company that markets products and sells digital software and services. It is controlled by Irish holding company Apple Operations International.

While tax is calculated as a proportion of profit, not revenue, multinational companies including Apple have been criticised for booking revenue offshore, in low-taxing places like Ireland or Singapore, to minimise their reportable profit and therefore their taxes in places like Australia.