August 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. 8 - 2017 of the Bulletin for International Taxation is now available online.

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Number 8 - 2017 contains the following:


The New Australia-Germany Income and Capital Tax Treaty (2015): A Tax Treaty for the Era of the OECD/G20 BEPS Initiative?

Michelle Markham

The new Australia-Germany Income and Capital Tax Treaty (2015) responds to the OECD recommendations in the Final Reports of the Base Erosion and Profit Shifting (BEPS) initiative. It is one of the first tax treaties concluded following the OECD/G20 BEPS initiative and the first to incorporate the final OECD recommendations.

International/European Union/OECD

Implementation of Agreements on International Assistance in Tax Collection: Avoiding the Complexity of a “Mirror” Approach

Ilse De Troyer

This article focuses on recent initiatives regarding international assistance in tax collection, the success of which is influenced by simplicity and complexity. A “mirror” approach is often adopted, whereby states aim for maximum equivalence in tax collection laws and practice, but the author does not think that this is ideal.

Argentina/Mexico/OECD/United Nations

The New Argentina-Mexico Income and Capital Tax Treaty (2015): A Tax Treaty in the BEPS Era

Daniel Fuentes Hernández and Mirna Solange Screpante

This article considers the Argentina-Mexico Income and Capital Tax Treaty (2015). In particular, the provisions on a permanent establishment, business profits, dividends, interest, royalties, avoidance of double taxation, anti-avoidance and the exchange of information are analysed. The implications of the OECD/G20 Base Erosion and Profit Shifting measures are also examined.

Available online only.



Tax Reform in Peru: Adopting Anti-Base Erosion and Profit Shifting Measures with a View to Membership of the OECD and More

Fernando Becerra O’Phelan

In this article, the author examines the various provisions that have been introduced into Peruvian tax legislation with a view to Peru becoming an OECD member country, with special focus on the adoption of anti-base erosion and profit shifting measures.


From Worldwide to Territorial Taxation: Is Italy Now an Attractive Destination for Migrating Individuals?

Giorgio Beretta

This article examines the Italian tax regimes offering favourable treatment to certain resident individuals. The recent introduction of these preferential regimes in a historical stronghold of worldwide taxation is a departure from the concept of unlimited tax liability, which results from other European states restricting their jurisdiction to tax.

International/European Union

Democracy, Revolution and Taxation

Frans Vanistendael

In this article, the author addresses the potential impact of recent populist political events on liberal democracy by answering five key questions from the point of view of European and international tax law.

United States/International/European Union/OECD

Conditional Withholding Tax: A Tax on Tax Planning

Jan Vleggeert and Henk Vording

This article discusses the merits of a conditional withholding tax on intra-group payments of interest and royalties. The authors argue that a conditional withholding tax would help to counter base erosion and profit shifting and would establish an international minimum norm for corporate income tax rates.