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   November 2016  
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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. 11 - 2016 of the Bulletin for International Taxation is now available online.

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Number 11 - 2016 contains the following:


Dutch Holding Companies Included in Brazilian Grey List: Controlled Foreign Company, Thin Capitalization and Consolidation Rules Not Applicable for 2015

Leonardo Freitas de Moraes e Castro

This article considers the material and temporal extent and effect of the changes to the Brazilian list of privileged tax regimes in relation to Dutch holding companies and, specifically, if these changes have implications for 2015 that affect filing in respect of the Escrituração Contábil Fiscal (Digital Accounting Register, ECF) in 2016.

European Union/International/OECD

International Tax Law Following the OECD/G20 Base Erosion and Profit Shifting Project

Christiana HJI Panayi

This article considers the implications of the OECD/G20 Base Erosion and Profit Shifting initiative on international tax law. It specifically questions whether the final deliverables address the problems identified at the inception of the initiative and examines the potential effects on the development of international and EU tax law.


The New Russian Controlled Foreign Company Regime: Review and Comparison with the Australian Regime

Nolan Cormac Sharkey and Evgeny Guglyuvatyy

Russia has recently introduced a controlled foreign company (CFC) regime. This article reviews the core features of the Russian CFC regime and provides a comparison with the Australian regime. This comparison helps in assessing the strengths and weaknesses of the new Russian CFC rules compared to the older Australian rules.

China (People’s Rep.)

Two Paths for Developing Controlled Foreign Corporation Rules in China

Yating Yang

In this article, the author discusses the different international tax policy considerations for outbound investments and inbound investments in China. In particular, the author argues that the current rough and broad-based controlled foreign corporation rules, together with their light enforcement, are best for China.


The Taxation of the “Sharing Economy”

Giorgio Beretta

This article investigates the phenomenon of the “sharing economy” from a tax policy perspective. In particular, the author analyses the tax challenges resulting from this new model of production and consumption and discusses possible tax policies to address development of the sharing economy.

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