May 2017  
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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. 5 - 2017 of the Bulletin for International Taxation is now available online.

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Number 5 - 2017 contains the following:
ARTICLES

International/OECD

Revised OECD Draft Guidance on the Profit Split Method: The Need for Conceptual Refinements!

Sunny Kishore Bilaney

This article provides a critical overview of the OECD’s revised draft guidance on the transfer pricing profit split method and makes important suggestions as to how to make the method more practical in its application.

Ireland/United Kingdom/OECD

The Relationship between Tax Authorities, Large Multinationals and the Public

Stephen Daly

In this article, the author explores accusations levelled at the revenue authorities of Ireland and the United Kingdom in response to their treatment of multinationals, analyses the statutory scheme underpinning the powers of those revenue authorities and provides a preliminary proposition as to why subsequent developments have been so distinct.

International/OECD

Is the OECD/G20 BEPS Initiative Heading in the Right Direction? Some Forgotten (and Uncomfortable) Questions

Eva Escribano

This article critically analyses the scope of the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative and further raises some questions concerning the role played by certain long-standing paradigms underlying corporate income taxation in the BEPS phenomenon.

China (People’s Rep.)/International/OECD

Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing

Jinyan Li and Stephen Ji

In this article, the authors consider location-specific advantages (LSAs) in transfer pricing analysis, with a special emphasis on the practice in China. They suggest that LSAs disrupt some of the basic assumptions underlying the current consensus on the application of the arm’s length principle without, arguably, violating the purpose of the principle as stated in article 9 of the OECD Model.

Portugal/European Union

Accounting and Tax Issues and the Portuguese Treatment of Intangibles with Indefinite Lives Following the Implementation of Directive (2013/34)

António Martins

Following the accounting changes for intangibles introduced by Directive (2013/34), this article considers if Portuguese legislation merely transposes the Directive’s rules or goes beyond what is required. The author also focuses on the tax treatment of these intangibles and analyses the sources of divergence between book and tax rules.

South Africa

The Venture Capital Company Regime in South Africa

Ernest Mazansky

In this article, the author describes how, after a slow start due to onerous requirements and low investment thresholds, investments in venture capital companies have taken off, resulting in significant funds being invested in small and medium-sized enterprises. The author also details current legal requirements and some issues requiring clarification.

Korea (Rep.)

Capital Gains Rollovers in Korea (Rep.)

Han Hui Yang and Richard Krever

The authors, in this article, review the Korean capital gains tax regime generally, illustrate how rollovers operate in Korea and consider the unique aspects of the Korean incorporation rollover.

International/European Union/OECD

An Evaluation of the Measures in Action 14 of the Action Plan of the OECD/G20 BEPS Initiative Intended to Make Dispute Resolution More Effective

Harsh Arora

Action 14 of the Action Plan, which is part of the OECD/G20 Base Erosion and Profit Shifting initiative, is intended to strengthen the mutual agreement procedure. This article discusses how these measures propose to minimize the risks of uncertainty and unintended double taxation.

Available online only 

European Union
The European Commission's Proposal for Double Taxation Dispute Resolution: Turning the Tide?
Filip Debelva and Joris Luts

The European Commission has recently published its proposal for a Council Directive on double taxation dispute resolution mechanisms. In this article, the authors conclude that, on balance, the Proposal is a welcome first step towards improving the position of the taxpayer in cross-border double taxation disputes.

Available online only

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