October 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. 10 - 2017 of the Bulletin for International Taxation is now available online.

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OECD Model Tax Convention and Key Features of Member Countries
Three essentials in one handy reference.
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Current Issues in International Tax Planning
21-23 February 2018
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Number 10 - 2017 contains the following:



The Influence of the OECD Multilateral Convention on Mexico’s Tax Treaties

Juan Angel Becerra

In this article, the author examines the influence of the OECD Multilateral Convention (MLI) with particular emphasis on the extent to which it will modify Mexico’s existing tax treaties and affect their interpretation and application as well as the relationship with its most important tax treaty partners.


Initiative and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS

Aline Berbari

In this article, the author considers the implications of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI”) for the OECD/G20 Base Erosion and Profit Shifting initiative in general, and specifically of the United States not signing the MLI.


Untangling the Role of Reservations in the OECD Multilateral Instrument: The OECD Legal Hybrids

Ricardo García Antón

By elaborating a typology and unearthing the effects of the MLI reservations, the author concludes that the OECD is shifting away from the Vienna Convention on the Law of Treaties to endorse unknown legal categories, thereby concealing the lack of consensus regarding how best to deal with base erosion and profit shifting practices.


Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, with Respect to Fiscally Transparent Entities - Part 2

Angelo Nikolakakis, Stephane 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 2 of this article concludes the authors' examination of 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, including a consideration of the relevant interpretive and technical questions, and policy issues.


Arbitration under the OECD Multilateral Instrument – Reservations, Options and Choices

H.M. Pit

Seventy states have signed the Multilateral Instrument (MLI). Part VI includes a mandatory and binding arbitration procedure for those issues that remain unresolved after two years under the mutual agreement procedure. This article considers the implication for the 26 states that to date have opted for Part VI.


Brazil/World Trade Organization

Brazil’s REINTEGRA in Light of World Trade Organization Rules: A Wrong Way to Incentivize Development?

Leonardo Aguirra de Andrade

This article considers the nature of the Brazilian Special Regime for the Reintegration of Tax Values for Exporting Companies (“REINTEGRA”), and its non-conformity with World Trade Organization rules, especially in relation to the concepts of subsidy and most-favoured nation and national treatment.

Available online only.

Bahrain/Kuwait/Oman/Qatar/Saudi Arabia/United Arab Emirates/Gulf Cooperation Council

The New VAT Regime in the Gulf Cooperation Council Countries

Yass Alkafaji and Omaima Khanfar

The authors, in this article, consider the significant aspects of the new VAT regime that the Gulf Cooperation Council (GCC) countries will institute effective 1 January 2018. Additionally, the authors discuss the nature of the new VAT regime and its implications for the GCC economies.

Available online only.

South Africa/International

Is There Evidence of Increasing Harmonization in the Interpretation of Tax Treaties by Courts in Their Reference to Foreign Court Decisions? A Study of South African Case Law

Rui Carvalho, Imran Daniels, Mike Dewar and Waleed Sahabodien

In this article, the authors consider the use by South African courts of the decisions and reasoning in the case law of other countries with regard to the South African interpretation of tax treaties and other international treaties and conventions seeking evidence of convergence or divergence in interpretations applied.

Available online only.