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   October 2015  
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Bulletin for International Taxation
 
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Issue No. 10 - 2015 of the Bulletin for International Taxation is now available online.

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Number 10 - 2015 contains the following:
ARTICLES
Denmark

Crowdfunding in Scandinavia

Susi Hjorth Bærentzen

In this article, the author explores the relatively new but rapidly growing phenomenon of crowdfunding in Scandinavia and, in particular, related developments and regulations in Denmark.

Brazil/Netherlands

No Brazilian Withholding Tax on Payments for Technical Services?

M.F. Furtado, H. Verboom and C. Lütter

This article considers the recently issued Brazilian Interpretative Declaratory Act on Brazilian withholding tax on payments for technical services, its effects, and leading and recent case law on this topic from a Brazilian tax perspective. The authors use the Netherlands as an example to illustrate a possible outcome of the Act, and discuss in which situation the imposition of Brazilian withholding tax can be challenged.

Australia

The Australian Offshore Banking Unit Regime: Modernizing the Rules

Anton Joseph

The author, in this article, explains the operation of the Offshore Banking Unit (OBU) regime in Australia before and after the recent amendments to it. The changes apply as from the beginning of July 2015.

International/Switzerland/United States

Taxation without Representation: The Case of Resident Non-Citizens

Giedre Lideikyte-Huber

In this article, the author examines the issue of taxation without representation as it relates to non-citizen taxpayers in the context of political and voting rights.

International

What Can the Tax Community Learn from Dispute Resolution Procedures in Non-Tax Agreements?

Jeffrey Owens, Laura Turcan, Jasmin Kollmann, Alicja Majdanska and Sudin Sabnis

In this article, the authors examine, from a tax perspective, various types of dispute resolution that are available under a number of non-tax instruments and bodies.

International/OECD

Human Capital in Value Creation and Post-BEPS Tax Policy: An Outlook

Romero J.S. Tavares and Jeffrey Owens

In this article, the authors propose the debate of “evolutionary” international tax reform, inter alia, revisiting the current discussion on base erosion and profit shifting (BEPS), and suggesting a renewed emphasis on knowledge-based capital within the framework of the arm’s length principle in respect of transfer pricing and other specific anti-avoidance rules.

OECD/International

OECD Base Erosion and Profit Shifting Action 6: The General Anti-Abuse Rule

Carlos Palao Taboada

In this article, the author examines Action 6 of the OECD Base Erosion and Profit Shifting (BEPS) initiative, with special regard for the proposed general anti-abuse rule (GAAR). In the author’s opinion, although some of the criticism raised against it is justified, the proposed rule is in line with similar rules in comparative law.

Qatar

Qatar and International Taxation: Part I - An Overview of the Legal and Tax Systems

Roberto Scalia

In Part I of this article, the author presents an overview of Qatar’s legal and tax systems, providing a context for these systems with regard to international taxation.

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