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   May 2016  
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Cross-Border Tax Expertise
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. 5 - 2016 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

[Conference]
70th Congress of the International Fiscal Association
25-30 September 2016,

Madrid
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[Course]
International Taxation of Banks and Financial Institutions
31 August - 2 September 2016
Amsterdam
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Number 5 - 2016 contains the following:
TAX TREATY MONITOR

International

The Principle of Territoriality and Corporate Income Taxation – Part 2

Adam Becker

In Part 2 of this article, the author examines to what extent unilateral tax relief and tax treaties conform to the principle of territoriality with regard to corporate income taxation.

Denmark/International/OECD

Permanent Establishments and the Offshore Oil and Gas Industry – Part 2

Maja Stubbe Gelineck

Following on from Part 1 of this article, which was published in Bulletin for International Taxation of April 2016, in Part 2 of the article, the author considers specific provisions involving the offshore oil and gas industry that are included in a number of tax treaties concluded by Denmark.

International/OECD

Administrative Requirements for Claiming Treaty Entitlement: Problems and Solutions

Yohanes Janitra Jaya

The author, in this article, considers various issues relating to the administrative requirements in respect of claiming treaty entitlement and benefits, and identifies the problems that may arise and suggests solutions to these problems.

Available online only

ARTICLES

Germany

Recent Developments Regarding Holding Companies in Germany

Stephan Kudert and Christian Kahlenberg

This article examines recent tax law developments in Germany. The primary focus is on court decisions, which are particularly relevant in connection with the activities of holding companies in Germany. Potential legislative developments in this area are also selectively addressed.

China (People’s Rep.)

Advance Pricing Agreements in China

Na Li

The author, in this article, describes the legal framework and current status of concluding advance pricing agreements (APAs) in China and considers possible development with regard to Chinese APAs.

International/OECD

Mind the Gap: The Role of Politics and the Impact of Cultural Differences on the OECD BEPS Project

Arkadiusz Myszkowski

In this article, the author considers the achievements of the OECD Base Erosion and Profit Shifting Project using socio-economic-political approaches, and attaching special attention to the failure to address problems related to the impact of cultural differences on the interpretation of anti-abuse provisions.

International

Report of the Proceedings of the Sixth Assembly of the International Association of Tax Judges Held on 4 and 5 September 2015

Zulema Rickenbacher-Omlin

This report summarizes the proceedings of the Sixth Assembly of the International Association of Tax Judges, held in Lucerne, Switzerland on 4 and 5 September 2015.

Brazil/OECD

Transfer Pricing in Brazil and Actions 8, 9, 10 and 13 of the OECD Base Erosion and Profit Shifting Initiative

Marcos Aurélio Pereira Valadão

Actions 8, 9, 10 and 13 of the OECD Base Erosion and Profit Shifting (BEPS) initiative directly relate to transfer pricing. This article discusses how the transfer pricing related outcomes of the BEPS Project could affect the Brazilian transfer pricing legislation and the particular Brazilian approach to this issue.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION
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