January 2015  
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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. 1 - 2015 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

[Book]

Tax Treaty Case Law around the Globe 2014

This book is a unique publication that discusses the 39 most important tax treaty cases which were decided by judges in 2013 around the globe.

Price: EUR 85 / USD 110 (VAT excl.)

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[Course]

Principles of International Taxation

Date: 20 - 24 April 2015
Location: Amsterdam - The Netherlands
Level: Introductory
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Number 1 - 2015 contains the following:
TAX TREATY MONITOR
Companion to the IBFD Treaties collection, available at http://online.ibfd.org/kbase
New Zealand
International Tax Policy Changes Arising from New Zealand’s Latest Tax Treaties: New Perceptions of Being a Capital Exporter?
Andrew M.C. Smith
In this article, the author reviews nine tax treaties recently concluded by New Zealand, explaining the key changes arising from these new tax treaties, and how they represent an important change in New Zealand’s international tax policy and indirectly signal how New Zealand views itself in the international economy.
International/Brazil/France/United States
Interpretative Treaty Override, Breach of Confidence and the Gradual Erosion of the Importance of Tax Treaties
João Victor Guedes Santos
This article addresses interpretative treaty override and its consequences for long-standing treaty networks. In particular, it reconciles the theory underlying tax treaties and the issues arising from Brazilian, French and US treaty practice to assess the effects of intentional misinterpretations and the reliance that taxpayers can place on treaty provisions.
Denmark/Sweden
Taxation of Cross-Border Employment Income and Tax Revenue Sharing in the Öresund Region
Mattias Dahlberg and Ali Sina Önder
In this article, the authors examine the current rules of the Nordic tax treaty for the taxation of cross-border employment income in the Öresund Region and their impact on public finances of local governments. They propose amendments to those rules since the asymmetry in commuter flow causes revenue losses in the Swedish County of Scania.
OECD
Entertainers and Sportspersons Following the Updated OECD Model (2014)
Dick Molenaar

The author, in this article, considers various problems arising from, the context and history of, and recent developments regarding, article 17 of the OECD Model on entertainers and sportspersons. He suggests a “solution” via a new text for article 17, which is supported by the 2014 Update to the OECD Model.

France/Luxembourg
Real Estate Investment and the France-Luxembourg Income and Capital Tax Treaty (1958): The End of an Era?
Julien Saïac
The Protocol (2014) to the France-Luxembourg Income and Capital Tax Treaty (1958) provides for the taxation of real estate income and capital gains in the state where the property is located, whether held, directly or indirectly, by an individual or a corporation, thereby blocking a well-known tax loophole.
TAX TREATY CASE LAW MONITOR
Companion to the IBFD Tax Treaty Case Law collection, available at http://online.ibfd.org/kbase/
International/India/Mexico/United Kingdom
Tax Treaty Case Law News
Brian J. Arnold

In this Tax Treaty Case Law News, Brian Arnold reviews recent cases from India, the United Kingdom and Mexico on fees for technical services, income from employment aboard aircraft and non-discrimination, respectively.

ARTICLES
European Union
Defining “Environmental Taxes”: Input from the Court of Justice of the European Union
Federica Pitrone
In this article, the author proposes a new approach to the definition of the term “environmental taxes”, taking into account a recent judgement of the Court of Justice of the European Union.
MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION