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   October 2016  
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Cross-Border Tax Expertise
Bulletin for International Taxation
 
This free e-mail service informs you about the contents of the forthcoming edition of Bulletin for International Taxation.

Issue No. 10 - 2016 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

[Conference]
International Taxation Conference 2016
1-3 December 2016
Mumbai, India
> Read more

[Course]

International Taxation of Expatriates
3-5 April 2017
Kuala Lumpur
> Read more



Number 10 - 2016 contains the following:
TAX TREATY MONITOR

International/OECD

Article 16 of the OECD Model: A Plea To Extend the Scope of the Ratione Personae

Andy Cools

In this article, the author presents arguments to extend the scope of the ratione personae of article 16 of the OECD Model beyond that of non-executive directors to include other directors.

ARTICLES

International/OECD

Understanding Risk in the Era of the OECD/G20 Base Erosion and Profit Shifting Initiative

Sunny Kishore Bilaney

The concept of “risk” is not new to transfer pricing, but different stakeholders have different perceptions, which may result in divergent views. The OECD/G20 in their Base Erosion and Profit Shifting initiative have created a framework to analyse risk in controlled transactions. This article examines this framework using practical examples.

European Union/International/OECD

The Effect of Anti-Avoidance Provisions Regarding the Promotion of Innovation: Considerations from a Tax Policy Perspective

Elizabeth Gil García

This article explores the options used to counter tax avoidance and aggressive tax planning, emphasizing the effect on fiscal measures designed to encourage innovation. Specifically, the author considers the different measures that are intended to ensure a fair balance between the protection of tax bases and the promotion of innovation.

International/OECD

Can Cooperative Compliance Help Developing Countries Address the Challenges of the OECD/G20 Base Erosion and Profit Shifting Initiative?

Jonathan Leigh Pemberton and Alicja Majdanska

Developing countries arguably have the most at stake in the efforts to counter base erosion and profit shifting, but face the biggest challenges. In this context, the authors address the question of whether cooperative compliance between tax administrations and taxpayers has a role to play in these efforts.

International/OECD

Thoughts on the Potential Effects of the OECD/G20 BEPS Action Plan on Collective Investment Vehicles – Part I

Moritz Scherleitner

In Part I of this article, the author sets out his thoughts on the potential effects for Collective Investment Vehicles of the relevant Actions in the OECD/G20 Base Erosion and Profit Shifting Action Plan.

Brazil

Permanent Establishments: The Latest Trends from the Brazilian Tax Authorities – A Case Law Update

Doris Canen

In this article, the author demonstrates how permanent establishments (PEs) are treated under Brazilian domestic tax legislation, and examines recent jurisprudence that has held that there are PEs where they were previously not considered to exist and how this could affect business activities in Brazil.

Available online only.

International/OECD

Special Tax Zones in Developing Countries and Global Tax Policy

Antti Laukkanen

In his previous article, the author examined special tax zones (STZs), primarily from the perspectives of the OECD and the European Union. In this article, the author focuses on STZs in developing countries and the global tax context with foreign direct investments, tax practices and tax policies.

Available online only.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION
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