February 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. 2 - 2015 of the Bulletin for International Taxation is now available online.

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Number 2 - 2015 contains the following:

Australia/China (People’s Rep.)/India/Japan/Korea (Rep.)/Singapore/United Kingdom

Tax Treaties and Temporary Residence for Individuals: Tax Abuse? – Focus on the Rules in Australia, China (People’s Rep.) and Singapore in the Context of the Tax Treaties between These States and with India, Japan, Korea (Rep.) and the United Kingdom

Nolan Cormac Sharkey

The author, in this article, examines the topic of tax treaties and temporary residence for individuals under domestic laws in relation to three Asia-Pacific states and whether the resulting reduction in international tax liabilities at the expense of other states can be justified or constitutes tax abuse.

China (People's Rep.)/Germany

The China-Germany Income and Capital Tax Treaty (2014) – An Analysis

Andreas Perdelwitz

In this article, the author considers the significant aspects of the China-Germany Income and Capital Tax Treaty (2014), specifically examining the articles on permanent establishments, business profits, dividends, interest, royalties and the avoidance of double taxation by the residence state.

International/European Union/Switzerland

The Rubik Model: An Alternative for Automatic Tax Information Exchange Regimes?

Vokhidjon Urinov

In this article, the author examines the nature and implications of a relatively recent phenomenon in the international tax system: Rubik agreements, with special consideration being given to whether or not such agreements are, in theory, equitable and fair in relation to all countries and taxpayers in contrast to automatic exchange of information agreements.

Available online only.



The Effect of the OECD Base Erosion and Profit Shifting Action Plan on Developing Countries

Leonard Wagenaar

In this article, the author describes some of the typical features of tax systems of developing countries and discusses how the OECD Base Erosion and Profit Shifting Initiative affects such countries and their tax systems.

United States

Structuring Foreign Investment in the United States

Jacob Stein

Inward US investment is typically motivated by the benefits of fiscal transparency, a well-developed political and legal system, economic stability, and the absence of currency controls, as well as the need for privacy, asset protection and minimal worldwide taxation.


Tax Aspects of Cross-Border Secondment of Employees to India

Vijay Krishnamurthy

In this article, the author examines the tax aspects of cross-border secondments of employees to India, with special reference to the significant tax implications for the foreign entities and Indian entities involved, as well as for the employees themselves.


Controlled Foreign Company Regimes in Brazil and Mexico: A Comparative Analysis

Andréa Marco Antonio

This article compares the history and characteristics of controlled foreign company regimes in Brazil and Mexico, specifically examining the compatibility of these regimes with tax treaties.


Capital Gains Tax for Non-Residents Comes under Significant Review

Anton Joseph

In this article, the author examines the Australian rules on the taxation of capital gains derived by non-residents on disposal of Australian real property.

Country-by-Country Reporting: A New Approach towards Book-Tax Conformity
Andrzej Stasio

In this article, the author argues that increased book-tax conformity can be achieved through improved documentation, in particular in the field of transfer pricing, and through country-by-country reporting.

Available online only.