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   December 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. 12 - 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]

Transfer Pricing and Intra-group Financing
23-24 February 2017
Amsterdam
> Read more



Number 12 - 2016 contains the following:
TAX TREATY MONITOR

OECD

The Proposed OECD Multilateral Instrument Amending Tax Treaties

Stéphane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Koichi Inoue, Jürgen Lüdicke, Guglielmo Maisto, Toshio Miyatake, Angelo Nikolakakis, Kees van Raad, Richard Vann and Bertil Wiman

In this article, the authors consider some of the practical issues relating to the introduction of the OECD multilateral instrument amending tax treaties, which has been proposed within the context of the OECD/G20 Base Erosion and Profit Shifting Project.

SPECIAL ISSUE ARTICLES

Ghana

Ghana’s Transfer Pricing Regime: The Current Situation and Suggestions for Improvement

Abdallah Ali-Nakyea and William Kofi Owusu Demitia

In this article, the authors examine the issues that are emerging following the recent introduction of Ghana’s transfer pricing regime, and propose the adoption of safe harbours to deal with the immediate and serious problems that could otherwise arise following the implementation of the regime.

Ethiopia/Ghana/Kenya/Malawi/ Netherlands/Zambia

Updating the Netherlands Treaty Network with African States: Better but Not Enough!

Ridha Hamzaoui

This article examines the tax treaties and amending protocols concluded by the Netherlands with African states following the publication in 2013 of its treaty policy note, with an emphasis on the balance between source and residence state taxation, new anti-avoidance rules and the OECD/G20 Base Erosion and Profit Shifting initiative.

East African Community/European Union

The East African Community Multilateral Tax Treaty – Fit for Purpose?

Johann Hattingh

In this article, the author reviews the background and provisions of the East African Community Multilateral Tax Treaty (2010), considers whether it is fit for purpose in today’s modern and ever-changing world, and draws comparisons to tax law developments in the European Union because of the similarity of the general EAC legal framework.

Angola/Cape Verde/Mozambique/

São Tomé and Príncipe

Portuguese-Speaking African Countries: Same Background, Different Solutions

Tiago Machado Graça

This article presents an overview of the international taxation aspects of the domestic tax legislations of Angola, Mozambique, Cape Verde, and São Tomé and Príncipe with regard to the direct taxation of companies.

Africa/International

Resolving Treaty Disputes: The Challenges of Mutual Agreement Procedures with a Special Focus on Issues for Developing Countries in Africa

Annet Wanyana Oguttu

This article explains the procedures and the responsibilities of the parties involved in mutual agreement procedures (MAPs), analyses the factors that can hinder their effective implementation and provides recommendations for addressing the challenges that developing countries in Africa may face.

Tanzania

Mining Taxation in Tanzania: The African Barrick Gold Cases

Attiya Waris

This article considers the changes made to Tanzanian mining law in relation to the issues that were highlighted in three recent cases involving the mining subsidiaries of African Barrick Gold, which concerned various tax issues. It then discusses how the cases elaborated on the tax law in question.

ARTICLES

International/OECD

International Taxation and Economic Substance

Sol Picciotto

This article argues that the “independent entity principle” is a basic flaw in the current system for taxing multinational enterprises (MNEs), creating problems especially for developing countries, which the OECD/G20 Base Erosion and Profit Shifting initiative has failed to resolve; it describes three alternative approaches that could be adopted to move towards a unitary approach to MNE taxation, and considers the prospects for the current transitional period.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION
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