June 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. 6 - 2016 of the Bulletin for International Taxation is now available online.

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

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Tax Accounting
28-30 September 2016
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Number 6 - 2016 contains the following:


Foreign Direct Investment in Developing Countries: Some Tax Considerations and Other Related Legal Matters

Khadija Baggerman-Noudari and René Offermanns

The authors, in this article, examine the tax implications of undertaking foreign direct investment in developing countries. Other matters relating to such investment are also considered by the authors.


New Rules on the Attribution of Profits to Permanent Establishments

Giorgio Beretta

In this article, the author examines both the former and new rules for the computation of income attributable to Italian permanent establishments and analyses the qualification of business income of non-resident enterprises under Italian tax law. Further, the recently enacted branch exemption regime, pursuant to which resident enterprises may opt for an exemption in respect of the profits of foreign PEs from the Italian tax base, is discussed.


OECD’s Action Plan on Tax Base Erosion and Profit Shifting: Part 2 – A Critique of Some Priority OECD Actions from an African Perspective – Addressing Excessive Interest Deductions, Treaty Abuse and the Avoidance of the Status of a Permanent Establishment

Annet Wanyana Oguttu

The author, in Part 2 of this article, continues her examination of the implications of the OECD’s Action Plan on Base Erosion and Profit Shifting from an African perspective, with particular emphasis on excessive interest deductions, treaty abuse and the avoidance of the status of a permanent establishment.

China (People’s Rep.)/Singapore

Renovating the Tax Base: The Development of Selected International Aspects of the Income Tax Regimes in Mainland China and Singapore with Reference to Hong Kong

Nolan Sharkey

In this article, the author discusses the development of selected international aspects of the income tax regimes in mainland China and Singapore since the end of the 1970s and what they may mean for the future in the two countries and Hong Kong.


Legal Uncertainty in the Application of the German CFC Rules

Stefan Weber and Martin Weiss

In this article, the authors describe the currently uncertain legal situation regarding the tax treatment of controlled foreign companies (CFCs) under German tax law. The authors focus on recent developments in the German tax treatment of CFCs and highlight consequences for investors in Germany.