March 2015  
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Issue No. 3 - 2015 of the Bulletin for International Taxation is now available online.

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Number 3 - 2015 contains the following:

United Nations

Report on the Tenth Session of the United Nations Committee of Experts on International Cooperation in Tax Matters

Brian J. Arnold

This article reports on the Tenth Session of the United Nations Committee of Experts on International Cooperation in Tax Matters regarding the various issues considered in relation to the next update of the UN Model and the Commentaries on the UN Model, which are planned to be published in 2017.


Treaty Shopping and Limitation on Benefits Articles in the Context of the OECD Base Erosion and Profit Shifting Project

Qunfang Jiang

The author, in this article, considers the concept of limitation on benefits articles as advanced by the OECD and the United States in relation to treaty shopping, with special emphasis on the implications of Action 6 of the OECD Base Erosion and Profit Shifting initiative.


The Role of the UN Model in Peru’s Tax Treaties

Khaled Luyo Acosta

In this article, the author examines the influence of the UN Model on Peru’s treaty practice, with particular emphasis on the extent to which Peru has adopted the provisions of the UN Model rather than those of the OECD Model.



Tax Policy Trends in Africa – Commentary on the Major Tax Developments in 2013 and 2014

Kennedy Munyandi, Ridha Hamzaoui, Carlos Gutiérrez Puente, Lydia Ogazón, Anapaula Trindade Marinho, Monica Montes, Monia Naoum and Emily Muyaa

The authors, in this article, comment on the most significant tax policy trends and developments that occurred in Africa in 2013 and 2014, together with providing an analysis, both theoretically and globally, of the relevant tax changes. The article also considers potential future tax policy developments in Africa.


Tax Amnesties as a Transitional Bridge to Automatic Exchange of Information

Vokhidjon Urinov

In this article, the author considers arguments for and against using tax amnesties as a way to transition effectively to the system of automatic exchange of information in accordance with the new global standard on automatic exchange of financial account information in tax matters as proposed by the G20 and the OECD.

South Africa

Hybrid Debt and Hybrid Equity Instruments and the Interest Limitation Rules in South Africa

Ernest Mazansky

In this article, the author examines the South African tax rules relating to hybrid debt and hybrid equity instruments, particularly with a view either to disallowing deductions or taxing receipts. Some observations are also made on the related interest limitation rules, which prevent excessive interest deductions.


German Federal Tax Court Again Questions Constitutionality of Treaty Override

Tobias Hagemann and Christian Kahlenberg

In a recently published decision, the German Federal Tax Court (Bundesfinanzhof, BFH) once again expressed doubts about the constitutionality of treaty overriding provisions. This article discusses the facts of the case and the reasoning of the Court, and provides a brief comment on the decision.


The Implementation of the “Authorised OECD Approach” under German Law and Its Relation to Tax Treaties Already in Force – Can the “Authorised OECD Approach” Be Applied Retrospectively
Rabea Katharina Lingier

In this article, the author examines the implementation of the Authorised OECD Approach (AOA) under German law and discusses whether the AOA can be applied retrospectively.

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