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White Papers

The IBFD’s Knowledge Centre regularly releases White Papers, which result from extensive research conducted by IBFD’s research staff. These Papers aim to enlighten the international tax community on matters of significant interest. Although all relevant aspects were critically analysed, your feedback is always welcome.


To view one of IBFD's free White Papers on the IBFD Tax Research Platform, click on the links below. You will need to sign in or register if you do not have an account. Your personal details in My Account must be complete in order to get access.

White Papers currently available:



Latvia: Individual Income Tax Rules for Virtual Currency Transactions


The author provides a brief outline of Latvia’s existing regulatory framework and discusses the proposed individual income tax rules for virtual currency transactions in Latvia.








BEPS in Latin America (Part II): A review of the implementation of Actions 2, 3, 4 and 12


This White Paper is a follow-up of the White Paper “BEPS in Latin America (Part I): A review of the implementation of minimum standards and the peer review process” and reviews the progress made by Latin American countries that have joined the Inclusive Framework in respect of the implementation of the OECD Base Erosion and Profit Shifting (BEPS) Actions 2, 3, 4 and 12.




McDonald’s – Limits on State Aid Control in Tax Ruling Investigations


According to the recent Commission decision in regard to McDonald’s, the tax rulings issued by Luxembourg in 2009 and allowing the non-taxation of McD Europe’s profits in Luxembourg, even when such profits were not taxed elsewhere (in particular in the United States), are in line with national law and the Luxembourg-United States Income and Capital Tax Treaty (1996) and therefore do not infringe EU State aid rules. The Commission found that the double non-taxation in the McDonald’s case is the result of a mismatch between the Luxembourg and the US tax laws and does not derive from a special treatment granted by Luxembourg. This paper provides the background, the facts and the Commission’s findings, and presents some follow-ups to the investigation



Closing the VAT Gap


The VAT gap exists due to the defects of the current VAT system, these imperfections leading to a decrease in collected tax revenues. There are several remedies, some of which are controversial. In this regard, the annual VAT gap reports reflect the progress towards making a robust VAT system.






Tax Ghosts: Spectres of the Shadow Economy


Tax ghosts, those dispiriting spooks of the fiscal system, are persistent spectres in the shadow economy. In this White Paper, the author describes various types of tax ghosts, discusses their impact, outlines current ghostbusting strategies and reviews the OECD’s recent recommendations for further work.

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Taxing Social Media Income – The Dutch Perspective


In this White Paper, the authors explain how social media content creators (bloggers, vloggers and YouTubers) earn money and outline potential consequences of social media activities under the Dutch income tax law.

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VAT and Holding Companies’ Involvement: Benefit of the Doubt?


On 5 July 2018, the ECJ ruled in its judgment in the case of Marle Participations (C-320/17) that a holding company's involvement in the management of its subsidiary should be defined as all transactions constituting an economic activity performed by a holding company for the benefit of its subsidiary. Although this judgment seems to provide guidance on when a holding company can be regarded as a VAT taxable person, whereby such a company is thus in principle able to deduct input VAT, this White Paper raises some questions as to whether this judgment really does provide guidance or whether it results in even more questions.    View this White Paper



European Commission – negative State aid decision with recovery in ENGIE


According to the Commission’s final decision in regard to Engie, two tax rulings issued by Luxembourg endorsed a domestic hybrid mismatch arrangement (i.e. the treatment of the same transaction as both debt and equity) leading to double non-taxation and, accordingly, granted to the beneficiary (Engie) a selective advantage resulting in incompatible State aid contrary to article 107 TFEU. This paper provides the background, briefly presents the facts and the line of reasoning and includes some follow-ups and comments.
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Tax Simplification: It’s Complicated


Tax codes are notoriously complex and, despite frequent calls for simplification, there seems to be no simple solution. In this White Paper, the author highlights the complexity of the US tax code, examines its causes and concludes that some complexity is unavoidable to ensure a comprehensive and fair tax system.
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South Dakota v. Wayfair - The Global Impact


On 21 June 2018, the US Supreme Court issued its highly anticipated decision in South Dakota v. Wayfair. The case was called the “tax case of the millennium” given its huge impact on the sales taxation of electronic commerce in the United States. This White Paper describes the Supreme Court’s decision, explains its impact on non-US businesses and puts the decision in the context of the current debate on the taxation of the digital economy.
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MLI – Its Entry into Force and the Consolidated Texts of Impacted Articles of the First Affected Treaties


In this White Paper, the authors present all changes affecting these treaties and include as annexes the consolidated texts of the relevant provisions, with modifications and supplements made by the MLI visibly incorporated.

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Taxation of the Digital Economy – the EU’s outlook


In this paper, the authors describe and comment on the European Commission’s two proposals for taxation of digital activities in the European Union and its recommendation to Member States on amending their tax treaties with third countries.

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Tax-Related Identity Theft


In this paper, the author describes tax-related identity theft, references recent cases of the crime, offers prevention recommendations and outlines the prescribed procedure for victims.

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Does the Tax Sector Need Blockchain?

Blockchain is frequently praised as a technological innovation that can be the panacea for all of the world's problems. In this paper, the author critically examines the usefulness of blockchain technology in the tax sector.

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Halfway towards Consensus or Chaos? Taxation of the digital economy at the crossroads

On 16 March 2018, the OECD presented its long-awaited interim report of the tax challenges arising from digitalization. The OECD stated that there is no consensus among countries on whether and to what extent changes to the current tax regime are needed; however, an agreement should be reached by 2020. In this White Paper, the author provides some comments on the recently issued interim report.

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Implementing the OECD/G20 BEPS Package in Developing Countries — An assessment of the priorities, experiences, challenges and needs of developing countries

This White Paper announces a report that IBFD prepared for the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) as part of its research and advisory work for the German Federal Ministry for Economic Cooperation and Development (BMZ). The aim of the report is to identify the priorities, experiences, challenges and needs of developing countries when implementing BEPS recommendations, specifically partner countries of German Development Cooperation (GDC), in order to assess where capacity building assistance is most needed. The report is divided in two main parts – a desk study and a survey study. The survey targeted GDC partner countries and was conducted in July and September 2017.

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Definitive system of reduced VAT rates – Too much freedom?

The recent proposal of the European Commission would greatly liberalize the system of reduced VAT rates. Although this approach is in line with the planned definitive VAT system, there are still questions of both a political and technical nature that need to be considered during future consultations.

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Revenue Losses due to VAT Gaps – A Study of Selected African Countries

This White Paper seeks to identify some of the causes of the VAT gap and proposes tools to ameliorate the VAT gap.

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BEPS in Latin America (Part I): A review of the implementation of minimum standards and the peer review process

This White Paper reviews the progress made by Latin American countries that have joined the Inclusive Framework in respect of the implementation of the BEPS minimum standards and the status of the peer review process they are subject to.

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Corporate Income Tax Reform in Latvia

The author provides a brief outline and analysis of the corporate income tax (CIT) reform in Latvia. The new CIT Law follows the Estonian CIT system, where CIT is paid on distributed profits. The classical system is abolished.

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Major Tax Developments of 2017

This White Paper summarizes some of the major tax developments of 2017. The authors discuss, among others, the US tax reform, the Brexit progress, the Paradise Papers, the Multilateral Instrument and the EU blacklist of non-cooperative jurisdictions.

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Prospects for a post-Brexit customs cooperation

This paper examines the vision of the United Kingdom and of the European Union in their respective approaches to the United Kingdom’s withdrawal from the Customs Union.

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New Chinese Rules on Special Tax Investigation Adjustments and Mutual Agreement Procedures

This White Paper reviews the recently released SAT Announcement [2017] on special tax adjustments and mutual agreement procedures.

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Will Trump’s Tax Reform Make America Great Again?

On 26 April 2017, the White House unveiled the core principles of Trump’s tax reform, which is meant to be “one of the biggest tax cuts in American history” and “the most significant tax reform since 1986”. This White Paper explains and comments on the reform proposal. 

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OECD Multilateral Convention: Flexibility versus the BEPS Project

The release of the OECD Multilateral Convention has revealed that states may decide to disregard many treaty-related measures of the OECD/G20 BEPS Project despite being signatories to it. This paper will look at the reasons behind such an astonishing degree of flexibility, not only in regard to the potential effectiveness of the Multilateral Convention but also in regard to its underlying objectives.

The text of the OECD Multilateral Convention (2016) is available and searchable on the IBFD Tax Research Platform.

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Trump’s Tax Plan

In this paper, the author provides a brief outline and analysis of Trump’s tax plan and draws comparisons with the tax plan proposed by House Republicans.
With the inauguration of President-elect Donald J. Trump at hand, there is considerable interest in and apprehension about his innumerable campaign promises. For this paper, the author limits his focus to Trump’s tax-related proposals, which include a reduction of the corporate income tax rate and a consolidation of the individual income tax brackets.

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US Treasury Department expresses concerns with European Commission’s State aid investigations

This white paper outlines the main concerns that the US Treasury Department has expressed with regard to the European Commission’s new approach in its State aid investigations of transfer pricing rulings issued by EU Member States.

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Tax Rulings and State Aid Investigations: The Apple Case

Since June 2013, the European Commission has been investigating the compatibility of tax rulings granted by the Member States with EU State aid law. On 30 August 2016, it concluded that Ireland granted undue tax benefits of up to EUR 13 billion to Apple. This White Paper examines and comments on the Commission’s policy on State aid, specifically with regard to the Apple case.

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European Union: Blacklists as a tool to fight tax avoidance

Blacklists are a commonly used instrument in the fight against tax avoidance. The European Union recognized the need for a uniform EU framework for addressing tax good governance concerns with third countries and initiated the development of a common EU list of noncooperative jurisdictions. This white paper provides a brief explanation of the EU policy on combating tax avoidance by means of blacklists.

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EU Anti-Tax Avoidance Directive – Overview and some prospective effects

On 12 July 2016, the Council of the European Union adopted the Anti-Tax Avoidance Directive (the Directive). The implementation of the rules in the Directive will have several tax consequences at the EU level. This paper provides some brief technical background, describing the adopted rules and their prospective effects.

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Tax Treaties: Time for a New Approach?

The author revisits the question of whether tax treaties are necessary, and the possible alternatives to the current bilateral regime. The scholarship of distinguished academics and prominent practitioners, on whether the present treaty architecture adequately meets the demands of the modern-day business and investment landscape, is parsed.

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