January/February 2016  
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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. 1/2 - 2016 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

[Conference]
IBFD's 2nd Africa Tax Symposium
Trends in International Taxation: An African Perspective

4-6 May 2016, Uganda
> Read more



[Course]
Transfer Pricing Valuation
31 March – 1 April 2016, Amsterdam
> Read more

Number 1/2 - 2016 contains the following:
EDITORIALS

International

Special Issue - Preface

Eugene P. Rossiter

International

Special Issue - Preface

Robert Jan Koopman

International

Very Small General Report

Peter J. Wattel

SPECIAL ISSUE ARTICLES
Australia

Tax Litigation in the Federal Court of Australia

Justice G.T. Pagone

This article provides an outline of the workings of the Australian judicial system, with special reference to the functioning of the Federal Court.

Belgium

The Court of Cassation as the Supreme Body of the Judiciary in Belgium

Myriam Ghyselen and Bernard Peeters

The authors, in this article, describe the organization and functioning of the Belgian Court of Cassation (Cour de cassation/Hof van Cassatie) and its importance for Belgian tax and treaty law.

Canada

An Overview of the Supreme Court of Canada

Justice Marshall Rothstein

The author, in this article, describes the organization and functioning of the Supreme Court of Canada and considers the significance of the Supreme Court with regard to the Canadian tax law.

France

The French Supreme Administrative Tax Court

Philippe Martin

This article describes the organization, mission, composition, functioning and significant decisions of the French Conseil d’Etat (Supreme Administrative Court), together with the importance of the CE for French domestic and international taxation.

Germany

The German Federal Fiscal Court: An Overview

Rudolf Mellinghoff

In this article, the author describes the organization and functioning of the German Bundesfinanzhof (Federal Fiscal Court) and his approach to select issues of German (international) tax law.

Italy

Tax Litigation before the Italian Supreme Court of Cassation: An Overview

Massimo Scuffi

This article provides an outline of the workings of the Italian judicial system, with special reference to the functioning of the Corte Suprema di Cassazione (Supreme Court of Cassation).

Netherlands

Tax Litigation in Last Instance in the Netherlands: The Tax Chamber of the Supreme Court

Peter J. Wattel

This article describes tax litigation in the Netherlands, especially the organization, functioning and judicial policy of, and access to, the Tax Chamber of the Supreme Court of the Netherlands.

Spain

Tax Litigation before the Spanish Supreme Court

Manuel Vicente Garzón Herrero and Luisa López-Yuste Padial

In this article, the authors describe the organization and functioning of the Spanish Supreme Court and consider the significance of the Supreme Court with regard to the Spanish tax law.

Sweden

The Swedish Supreme Administrative Court: Adjudicating in Tax Matters

Roger Persson Österman

In this article, the author describes the functioning and organization of the Swedish Högsta förvaltningsdomstolen (Supreme Administrative Court), together with its significance regarding Swedish taxation.

Switzerland

Tax Litigation before the Swiss Supreme Court

Thomas Stadelmann

The author, in this article, describes the organization and functioning of the Schweizerisches Bundesgericht/Tribunal fédéral suisse (Swiss Federal Supreme Court) and considers its significance with regard to the Swiss Constitution and Swiss tax law.

United Kingdom

Tax Appeals in the UK Supreme Court

Malcolm Gammie

This article examines the system of tax appeals in the United Kingdom, with special reference to the appeals heard by the Supreme Court.

United States

The United States Tax Court: A Court for All Parties

Keith Fogg

This article seeks to explain the role of the Tax Court both within the system of taxation and the system of tribunals of the United States.

ARTICLES

International/OECD

Seeking New Directions in Dispute Resolution Mechanisms: Do We Need a Revised Mutual Agreement Procedure?

Michelle Markham

This article examines issues in reforming the mutual agreement procedure (MAP), drawing on concerns raised by various organizations, especially the OECD. It evaluates perceived obstacles to the functioning of this aspect of the global tax environment and considers new directions in reforming the MAP process that could enhance controversy management.

International/OECD

The Compatibility of the OECD/G20 Base Erosion and Profit Shifting Proposals with EU Law

Christiana HJI Panayi

This article examines the compatibility of the proposals produced in respect of the OECD/G20 Base Erosion and Profiting Shifting Action Plan with EU law. Where relevant, the author also reviews the compatibility of the recent EU measures that address aggressive tax planning.

European Union/International/OECD

Final Report on Action 6 of the OECD/G20 Base Erosion and Profit Shifting Initiative: Prevention of Treaty Abuse

Erik Pinetz

The author, in this article, analyses the Final Report on Action 6 on “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances” of the OECD/G20 Base Erosion and Profit Shifting initiative, especially with regard to the recommended inclusion of a principal purpose test and a new preamble in future tax treaties.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION