September 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. 9 - 2017 of the Bulletin for International Taxation is now available online.

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Number 9 - 2017 contains the following:

Brazil/OECD/United Nations

The Taxation of Non-Resident Rental Income from Movable Property in the Tax Treaties Concluded by Brazil

Sergio André Rocha

In this article, the author considers the implication of the taxation of rental income and royalties that are derived by non-residents in relation to the OECD Model the UN Model, and the tax treaties that Brazil has concluded.


Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, with Respect to Fiscally Transparent Entities – Part 1

Angelo Nikolakakis, Stéphane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Johann Hattingh, Koichi Inoue, Jürgen Lüdicke, Guglielmo Maisto, Toshio Miyatake, Kees van Raad, Richard Vann and Bertil Wiman

Part 1 of this article reflects on the OECD’s proposals regarding fiscally transparent entities and the provisions of the Multilateral Instrument based on experience in considering and working with similar measures in existing treaties. Consequently, the article raises a number of interpretive and technical questions, as well as policy issues.



New Advance Pricing Agreement Roll-Back Provisions in Turkey

Tahir Erdem

In this article, the author examines the new advance pricing agreement roll-back mechanism that has recently been introduced into the Turkish tax system, together with some other significant amendments to the Turkish transfer pricing rules.

Australia/United Kingdom/International

Australia’s New Diverted Profits Tax: The Rationale, the Expectations and the Unknowns

H. Khiem (Jonathan) Nguyen

This article discusses the rationale, the elements, the expected outcomes and the concerns in relation to the introduction of the new diverted profits tax (DPT) in Australia. The DPT applies from 1 July 2017.


The Profit Split Method: Deciphering the OECD’s 2017 Discussion Draft

Sunny Kishore Bilaney

This article provides a critical overview of the OECD’s revised draft guidance of 2017 on the profit split method. In this context, the author suggests important ways in which to make the method more practical in its application.

Available online only.


Mutual Assistance in the Collection of Taxes

Louise Parker

Increasing globalization and the growing mobility of taxpayers present new challenges for tax collection. In this article, the author assesses potential problems of the practical application of tax collection assistance provisions as well as their efficacy in curbing tax evasion.

Available online only.

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