March/April 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. 3/4 - 2017 of the Bulletin for International Taxation is now available online.

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Number 3/4 - 2017 contains the following:

International/OECD/United Nations

The UN Committee of Experts and the UN Model: Recent Developments

Brian J. Arnold

This article reports on the Twelfth and Thirteenth Sessions of the UN Committee of Experts on International Cooperation in Tax Matters regarding the various issues considered in relation to the next update of the UN Model and the Commentaries on the UN Model, which are planned to be published later this year.

Uruguay/OECD/United Nations

Uruguay’s Treaty Policy

Rodrigo Barrios Correa

This article considers Uruguay's treaty policy and negotiating process, and attempts to place the tax treaties that Uruguay has concluded to date in the context of the provisions of the OECD Model and the UN Model.


Taxation of Remuneration from Employment aboard a Ship or Aircraft Operated in International Traffic: Interpretation Issues under Article 15(3) of the OECD Model

Luc De Broe and Joris Luts

In this article, the authors consider the interpretation of article 15(3) of the OECD Model regarding the taxation of remuneration from employment aboard a ship or aircraft operated in international traffic as well as the effects of the changes proposed in the OECD Discussion draft of 2013.


An Analysis of the Rules on the Taxation of Investment Income under Japan’s Tax Treaties

Hiroyuki Kimura

The author, in this article, analyses the rules on the taxation of investment income under the tax treaties that Japan has concluded, focusing specifically on the development of Japan’s treaty policy over the years and its deviations from the OECD Model.

International/OECD/United Nations

How “Limited” Is Limited Force of Attraction? An Analysis of the Relevant Case Law and the Potential Implications of the OECD/G20 BEPS Initiative

Suhas Sagar

This article considers the scope of the limited force of attraction principle as set out in article 7 of the UN Model, focusing on its development, the relevant case law and the potential implications for the principle in the light of the OECD/G20 Base Erosion and Profit Shifting initiative.


The Effect of the OECD/G20 BEPS Initiative on the Attribution of Profits to Permanent Establishments: The Special Case of Agency Permanent Establishments

Dinis Tracana

In this article, the author examines the effects of the OECD/G20 Base Erosion and Profit Shifting initiative on the attribution of profits to agency permanent establishments, focusing on the OECD’s Additional Guidance on the Attribution of Profits to Permanent Establishments, Action 7 - 2016 Public Discussion Draft.


What Is the Scope of the Concept of “Income” in Article 16 of the OECD Model?

Andy Cools

The author, in this article, further examines the scope of article 16 of the OECD Model and specifically considers what items of income should be regarded as being directors’ fees.

Available online only
European Union/OECD
The Changing Contours of Dispute Resolution in the International Tax World: Comparing the OECD Multilateral Instrument and the Proposed EU Arbitration Directive
Sriram Govind and Laura Turcan

This article considers the most significant changes proposed in the Multilateral Instrument and the EU Arbitration Directive and compares their scope and effectiveness along with their interaction so as to point out issues and to propose recommendations for more uniformly acceptable solutions.

Available online only


The Multilateral Instrument from a Legal Perspective: What May Be the Challenges?

Johann Hattingh

In this article, the author provides a brief legal evaluation of the Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) and considers the general legal and tax technical issues that may arise with regard to the language of its provisions.

Available online only
Action 6 of the OECD/BEPS Initiative: The Effect on Holding Companies
Radhika Karadkar

This article considers the anti-avoidance measures suggested by the OECD/G20 Base Erosion and Profit Shifting initiative and their impact on holding companies, particularly regarding financing responsibilities in respect of multinational groups, whether for the purpose of interest deductions at the level of the subsidiary or financing the development of intellectual property.

Available online only


Guidance on the Application of the Principal Purpose Test in Tax Treaties

Valentyn Kolosov

This article considers the impact of the principal purpose test, which Action 6 of the OECD/G20 Base Erosion and Profit Shifting initiative has proposed should be included in tax treaties, the certainty it offers with regard to legitimate tax planning and various sources of guidance for its application.

Available online only


The “Other Income” Article in Tax Treaties as Interpreted by the Courts: A Case Law Analysis

Eduardo Orellana Polo

In this article, the author considers how the scope of the “other income” article in tax treaties, and in the OECD Model, has been interpreted by various courts around the world.

Available online only


Analysis of the Case Law on the Scope of Article 17 of the OECD Model: Issues Resolved and Yet to Be Resolved

Luis Alberto Romero Topete

This article examines the case law surrounding the scope of article 17 of the OECD Model, the issues that have been resolved and those that are yet to be resolved.

Available online only