April 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. 4 - 2016 of the Bulletin for International Taxation is now available online.

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[Conference]
10th Asia/Africa IFA Conference
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Global VAT
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Number 4 - 2016 contains the following:
SPECIAL ISSUE ARTICLES

International

The Principle of Territoriality and Corporate Income Taxation – Part 1

Adam Becker

The author, in Part 1 of this article, considers the principle of territoriality with regard to corporate income taxation and specifically whether this principle is followed in practice by countries.

United Kingdom/United States

Pension from World Bank Staff Retirement Plan Tax Exempt in United Kingdom under the United Kingdom-United States Income Tax Treaty (2001)

Brian Cleave

In this article, the author analyses the recent UK tax case of Michael Macklin (2015) in which the Upper Tribunal held that a pension derived from the World Bank Staff Retirement Plan by a UK resident was exempt from tax in United Kingdom because that Plan was established in, and generally exempt from income taxation in, the United States for the purposes of the United Kingdom-United States Income Tax Treaty (2001).

International/OECD

Permanent Establishments and the Offshore Oil and Gas Industry – Part 1

Maja Stubbe Gelineck

Part 1 of this article discusses the concept of a permanent establishment (PE) regarding offshore oil and gas activities, specifically focusing on when offshore activity satisfies the criteria for a PE under the OECD Model and analysing whether a vessel can be a PE.

South Africa

South African Supreme Court of Appeal Confirms Application of Protocol to a Tax Treaty to Period before Signature Date

Ernest Mazansky

The author, in this article, considers the implications of the recent Supreme Court of Appeal of South Africa decision in Krok and Another (2015), in which the Court confirmed the retroactive application of a protocol to a tax treaty to matters that arose before the protocol was concluded.

International/OECD

Minimum Threshold for Entertainers and Sportspersons in Article 17 of the OECD Model

Dick Molenaar

This article considers the implications of article 17 of the OECD for lesser-known entertainers and sportspersons, especially with regard to the use of de minimis thresholds for the imposition of withholding tax on such individuals as contained in, inter alia, the Commentary on Article 17 of the OECD Model (2014).

ASEAN/International

Mutual Agreement Procedure Arbitration in Developing Countries - The ASEAN Experience

Zaleha Adam

This article examines mutual agreement procedure (MAP) arbitration in general and in developing countries, with a particular focus on MAP experiences of the countries forming the Association of South-East Asian Nations (ASEAN).

Available online only
ARTICLES

Saudi Arabia

Taxation of Foreign Multinational Enterprises Conducting Business in and with Saudi Arabia

Vladimir A. Gidirim

In this article, the author considers the tax implications of Saudi Arabian domestic law (outbound payments, permanent establishment issues) and the tax treaties that Saudi Arabia has concluded for multinational enterprises doing business in and with Saudi Arabia. The article also provides insights into the practices of local tax authorities.

International/OECD

The BEPS Package: Promise Kept

Pascal Saint-Amans and Raffaele Russo

This article considers the work already undertaken by the G20 and OECD member countries in developing the BEPS Action Plan, discusses the implementation of this ambitious initiative and concludes that the final outcome represents a restoration of integrity and coherence to the international tax system.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION