September 2015  
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Bulletin for International Taxation
 
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Issue No. 9 - 2015 of the Bulletin for International Taxation is now available online.

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Number 9 - 2015 contains the following:
TAX TREATY CASE LAW MONITOR

South Africa

South African Tax Court Departs from Commentary on Article 5 of the OECD Model in Finding a Permanent Establishment

Ernest Mazansky

In this article, the author considers a recent decision of the South African Tax Court, which might be considered controversial in some quarters, concerning whether or not a US company had a permanent establishment in South Africa.

ARTICLES

Germany

Tax Classification of Debt and Equity and Recent Jurisprudence in Germany

Sven-Eric Bärsch & Marcel Olbert

This article considers the relevance of the distinction between interest-generating debt and dividend-generating equity from a German tax perspective and presents an overview of the recent German jurisprudence on that matter.

International/Netherlands

Two Missing Links: A Move towards an Auditing Standard Specifically for the Tax Control Framework

Eelco van der Enden & Jos de Groot

In this article, the authors examine the importance of a global auditing standard for the Tax Control Framework in cooperative compliance environments and beyond. Specifically, they submit that, in order to provide greater assurance on the fiscal “in control” statement, this should be accompanied by assurance reporting from an external or internal auditor.

Japan/OECD

Introduction of the Authorised OECD Approach into Japanese Domestic Law

Yoshihiro Masui

In this article, the author discusses the background, core elements and implications of the 2014 tax reform in Japan, which introduced the Authorised OECD Approach (AOA) into Japan’s domestic law.

India

Transfer Pricing Aspects of Marketing Intangibles: An Indian Perspective

Sagar Wagh

In this article, the author considers the transfer pricing aspects of marketing intangibles from an Indian viewpoint, with particular emphasis on the controversy surrounding this subject. The author also analyses recent developments on the transfer pricing of marketing intangibles with regard to the OECD’s Base Erosion and Profit Shifting (BEPS) project.

China (People’s Rep.)/United States

The Taxation of Foreigners Working in China

James G.S. Yang

This article examines the taxation of foreigners working in China and notes that tax law classifies income as ordinary and investment income. The article also considers Chinese versus foreign-source income, income effectively connected with a Chinese trade or business and foreign tax credits, and compares Chinese and US tax rules.

International/European Union/OECD

Centralized Intellectual Property Business Models – Tax Implications of EU Patent Box Regimes

Ivan Zammit

This article provides a broad overview of the developments at the global and EU level regarding the tax effects of the adoption of centralized intellectual property business models. In this respect, the author specifically addresses patent box regimes and measures to counter aggressive tax planning and harmful tax competition.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION