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   August 2015  
BIT Preview IBFD, Your Portal to
Cross-Border Tax Expertise
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. 8 - 2015 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

[Conference]
69th Congress of the International Fiscal Association
30 August - 3 September, Basel. Visit us at booth 17 and register for the IBFD Dialogues on International Taxation.
> Read more

[Course]
Tax Planning and Substance
Amsterdam
21-22 September 2015
> Read more

Number 8 - 2015 contains the following:
TAX TREATY MONITOR

International/OECD

Emissions Trading and Tax Treaties
Roland Ismer and Manuel Haussner

Various countries have either contemplated introducing or implemented emissions trading schemes to mitigate climate change. Such schemes raise questions not only in relation to accounting and domestic taxation, but also regarding tax treaties that can be satisfactorily resolved by clarifications in the Commentaries on the OECD Model and UN Model.

ARTICLES
International
Location-Specific Advantages: When and How They Should Be Allocated
Sunny Bilaney

In this article, the author explains the concept of location-specific advantages, analyses when and how they should be allocated between multinational enterprise (MNE) groups based on the guidance provided in the United Nations Practical Manual on Transfer Pricing for Developing Countries (the UN Manual), Action 8 of the Action Plan on Base Erosion and Profit Shifting (Action 8), and in light of recent case law. Further, the approach adopted by the Indian and Chinese authorities is discussed.

European Union/Netherlands

The Effect of Taxation on Business Mobility in the European Union: The Case of the Netherlands
Loes Brilman

This article considers how Dutch exit taxation affects business mobility regarding the emigration and the immigration of a business, the transfer of assets in “permanent establishment situations”, alternative means of business migration, and whether the current Dutch tax system contravenes treaty and EU law. It also provides suggestions for improvement.

Brazil

The Brazilian Tax Implications of Cross-Border Remittances Arising from International Cost-Sharing Arrangements
Leonardo Freitas de Moraes e Castro

In this article, the author considers the international tax implications for the parties involved of international cost-sharing arrangements and, in particular, the arguments supporting the non-imposition of various Brazilian taxes with regard to payments made in relation to such agreements.

Netherlands

Housing Taxation: The Special Case of the Netherlands
Sigrid Hemels and Anneke Monsma

In this article, the authors examine the peculiarities of the Dutch housing systems with specific reference to its implications for both national and local taxation in the Netherlands.

Poland

New Polish Controlled Foreign Company Rules
Filip Majdowski and Weronika Missala

In this article, the authors examine the recently introduced Polish controlled foreign company rules and provide a detailed description of the new legislation against such rules in other countries together with a brief reference to the latest OECD initiative on base erosion and profit shifting.

International/OECD/Zambia

Bittersweet (Tax) Symphony
Li Shao Wu
This article reviews the tax structure discussed in a report published by Action Aid in 2013. The primary focus is on how domestic rules and tax treaties reduce effective tax rates. The author also discusses recent developments on the part of the OECD regarding its Base Erosion and Profit Shifting initiative.
MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION
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