February 2019  
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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. 2 - 2019 of the Bulletin for International Taxation is now available online.

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Number 2 - 2019 contains the following:

OECD/United Nations

New Article 12A of the UN Model Regarding Fees for Technical Services: Ahead of Its Time or a Step Too Far?

Monique T. Malan

This article analyses the key features of the new article 12A (Fees for technical services) of the UN Model (2017) and the pre-existing principles that these features question. Inconsistencies exacerbated by the introduction of article 12A are discussed and the two alternatives advanced in the Commentary on Article 12A evaluated.



Can the Brazilian Mutual Agreement Procedure Legislation Be Effective Domestically?

Doris Canen and Henrique de Conti

This article examines the new Brazilian legislation in respect of mutual agreement procedures in light of the changes proposed by Action 14 of the OECD/G20 BEPS initiative and considers whether such legislation can be effective in the country.

European Union/OECD/International

Taxation of Investment Funds Following the OECD Base Erosion and Profit Shifting Initiative – Part 1

Martine Merten

In Part 1 of this article, the author reviews the taxation of investment funds in light of the various changes and reforms proposed by the OECD/G20 BEPS initiative.

Luxembourg/European Union/OECD/International

Exchange of Information on Request: Whenever, Wherever? Shakira’s (and Berlioz’s) Right to Judicial Review of the Foreseeable Relevance Standard

Bob Michel

The author analyses the negative impact of the Global Forum peer review of Luxembourg on taxpayers’ right of judicial review of the foreseeable relevance of incoming requests for information. Recent case law at the European and national level is analysed, leading to the conclusion that such review is compulsory in EU Member States, which could affect the future direction of the Global Forum in the matter of taxpayer rights regarding the exchange of information on request.

European Union/OECD/International

The Emergence of Esports

Sebastiaan van Overbeek and Dick Molenaar

In this article, the authors discuss what esports games exist, how they are played, which types of income are relevant for the various games and what are the tax consequences.


Pakistan’s Efforts to Implement the Common Reporting Standard

Bilal Hassan

In this article, the author reviews Pakistan’s efforts to implement the Common Reporting Standard so as to be able to counter tax evasion.

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