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   November 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. 11 - 2015 of the Bulletin for International Taxation is now available online.

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Number 11 - 2015 contains the following:
TAX TREATY MONITOR

International/OECD

The Retroactive Effect of Changes to the Commentaries on the OECD Model

Dirk M. Broekhuijsen and Koen M. van der Velde

This article discusses the temporal aspects of tax treaties. In particular, it focuses on whether the legitimate expectations of taxpayers are harmed when changes are made to the Commentaries on the OECD Model. How are taxpayers’ rights considered when they have already entered into a certain factual or legal position?

ARTICLES

Lebanon

The Tax and Legal System of Lebanon – The Undiscovered Potential of a Country at a Crossroads

Damian Gwóźdź

The purpose of this article is to present a short description of the tax and legal system in Lebanon, a country that may be regarded by investors as the first step into the Middle East market.

International

Do Tax Treaties Embody the Application of Sovereign Immunity? – An Assessment with Regard to Sovereign Wealth Funds

Sally-Ann Joseph

This article concludes that a consideration of tax treaties with regard to sovereign immunity reveals that such treaties do not embody the doctrine of sovereign immunity. Governments with sovereign wealth funds should, therefore, negotiate a specific article in their tax treaties to provide certainty of tax treatment.

European Union/Netherlands/OECD

The Netherlands Court of Audit: An Audit on Tax Avoidance

Harry Koot and Marjan de Rijke

In this article, the authors describe, from an international perspective, the procedures performed by the Netherlands Court of Audit with regard to tax collection, and address recent initiatives of the international community to counter tax avoidance by multinational enterprises.

International/OECD

OECD’s Action Plan on Tax Base Erosion and Profit Shifting: Part 1 - What Should Be Africa’s Response?

Annet Wanyana Oguttu

In Part 1 of this article, the author first explains the thinking and concepts behind the OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) and then addresses the relevance of the OECD BEPS Action Plan to Africa and what should be the African response to the Plan.

Qatar

Qatar and International Taxation: Part II – The Income Tax Law and the Qatar Financial Centre Tax Regulations

Roberto Scalia

In Part II of this article, the author focuses on the Qatari income tax system with specific emphasis on the Income Tax Law (ITL) and the QFC Tax Regulations (QFC-TR).

United States

The Adverse Effects of Corporate Inversions in the United States

James G.S. Yang

This article discusses “corporate inversions”, which are a tax strategy that takes advantage of a lower tax rate in another foreign country. In this context, the article notes that corporate inversions have significant adverse effects in the United States that result from deficiencies in the US tax system.

Brazil

The Brazilian Thin Capitalization Rules and Tax Treaties: A Critical Approach

Alexandre Luiz Moraes do Rêgo Monteiro

In this article, the author examines thin capitalization rules in general and, in particular, those introduced by Brazil by way of Law 12,249/2010, and the relationship of these rules with the provisions of tax treaties, specifically, the equivalents of articles 9(1), and 24(4) and (5) of the OECD Model.

Available online only.
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