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   September 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. 9 - 2016 of the Bulletin for International Taxation is now available online.

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Number 9 - 2016 contains the following:
ARTICLES

Brazil/International

Exchange of Tax-Related Information and the Protection of Taxpayer Rights: General Comments and the Brazilian Perspective

Sergio André Rocha

This article examines certain specific points relating to the protection of the rights of taxpayers within the context of the exchange of information for tax purposes, with emphasis on the Brazilian experience. In this respect, the author considers both automatic exchange and exchange on request.

China (People’s Rep.)

Chinese Taxation on the Move

Wang Jun

In this article, Wang Jun, Commissioner of the State Administration of Taxation of the People’s Republic of China, comments on recent and upcoming important developments regarding Chinese taxation.

International/OECD

The Proposed Tiebreaker Rule in OECD/G20 BEPS Action 6: A Critical Examination of the Possible Motives and Means, and a Potential Alternative

Dhruv Sanghavi

In this article, the author critically examines the proposed tiebreaker rule in the OECD’s Final Report on Action 6 of the Base Erosion and Profit Shifting (BEPS) project, and the motives behind the proposal. The author concludes by suggesting an alternative, which he argues is a more effective means to achieve the intended ends.

Australia/Hong Kong/New Zealand

Comparative Tax Policy Approaches in Australia and New Zealand: Instructional Guidance for Hong Kong?

Adrian J. Sawyer

This article offers insights from Australia and New Zealand that could potentially inform the debate in the Hong Kong Special Administrative Region (HKSAR) with regard to tax reform, especially in respect of the HKSAR’s long-term revenue planning and recent proposals for more enhanced tax policy development.

India/OECD

The Taxation of Digital Transactions in India: The New Equalization Levy

Sagar Wagh

This article discusses the international work on the taxation of the digital economy with a specific focus on the Indian provisions with regard to the taxation of digital transactions, especially the recently introduced equalization levy. The author also considers Indian and international case law on this subject.

International/OECD/Australia/China/
Spain/United Kingdom

Tax Codes of Conduct: Fit for Purpose?

Eelco van der Enden, Kuralay Baisalbayeva and Katarzyna Bronżewska

In this article, the authors consider corporate governance and Tax Codes of Conduct in general, the specific tax perspective of corporate governance and the various roles that such instruments may play. The authors also examine particular country practices in this area.

Available online only

Brazil

The Social Contribution on Net Profits and the Substantive Scope of Brazilian Tax Treaties – Treaty Override or Legislative Interpretation?

João Francisco Bianco and Ramon Tomazela Santos

This article considers aspects of the social contribution on net profits (contribuição social sobre o lucro liquido, CSLL) in relation to the substantive scope of tax treaties concluded by Brazil and, inter alia, whether the enactment of a domestic law dealing with the application of the CSLL involves a treaty override or simply a legislative interpretation.

Available online only
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