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   January 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. 1 - 2017 of the Bulletin for International Taxation is now available online.

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3rd IBFD Africa Tax Symposium
10-12 May 2017
Accra, Ghana
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Number 1 - 2017 contains the following:
TAX TREATY MONITOR

Germany/South Africa

Recent Developments Regarding the Taxation of Pensions under Tax Treaties from a German and a South African Perspective

Tobias Hagemann, Johann Hattingh and Christian Kahlenberg

This article considers the taxation of cross-border pension payments from the perspective of Germany and South Africa in light of recent case law in Germany, and tax treaty law and relevant domestic law developments in the two countries.

ARTICLES

India/OECD

Indian Transfer Pricing Round-Up for 2016

Sunny Kishore Bilaney

In this article, the author analyses the significant developments in Indian transfer pricing rules in 2016, including amendments to existing regulations to align these with the OECD/G20 Base Erosion and Profit Shifting initiative, relevant court decisions, the success of the Indian advance pricing agreement programme, and changes regarding related-party transactions.

Argentina/Chile/Colombia/Mexico/United States

A Comparative Analysis of the Indirect Foreign Tax Credit in Latin America and in the United States - Part I

Diana Calderón Manrique

This article compares the indirect foreign tax credit systems applied in Latin America and the United States. Part I deals with Argentina, Chile and Colombia. Part II considers Mexico and the United States. It then compares these systems and examines the policy issues arising, before offering some conclusions and recommendations.

Hong Kong/Singapore/International/OECD

The Territoriality Principle in the World of the OECD/G20 Base Erosion and Profit Shifting Initiative: The Cases of Hong Kong and Singapore - Part I

Wei Hwa See

This article analyses the international tax issues encountered by states with territorial corporate tax systems, with specific reference to the systems of Hong Kong and Singapore. In Part I, the author examines the concept of territoriality and categorizes tax systems based on their degree of adherence to the territoriality priciple.

Switzerland/European Union/OECD

The Swiss Tax Ruling Practice: Recent Domestic and International Developments

Julian Kläser

In today's tax world, tax rulings are often considered obstacles to transparency and the fight against tax avoidance. Ever since LuxLeaks, the low level of transparency in corporate taxation has been recognized in the public debate. In this article, the author examines the Swiss ruling practice from both a domestic and an international perspective, with a special focus on the effects of the OECD/G20 Base Erosion and Profit Shifting initiative on the ruling practice.

Available online only.

Brazil/International/OECD

Action 14 of the OECD/G20 Base Erosion and Profit Shifting Initiative: Making Dispute Resolution More Effective – Did Action 14 “Piggyback” on the Initiative?

Phelippe Toledo Pires de Oliveira

This article examines Action 14 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative with regard to making dispute resolution more effective in respect of mutual agreement procedures and whether Action 14 is an integral part of the BEPS Action Plan or has simply been tacked onto the initiative.

Available online only.
MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION
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