December 2017  
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Bulletin for International Taxation
 
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Issue No. 12 - 2017 of the Bulletin for International Taxation is now available online.

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Number 12 - 2017 contains the following:
TAX TREATY MONITOR

International/Sweden/OECD

The Commentaries on the OECD Model as a Mechanism for Interpretation with Reference to the Swedish Perspective

Katia Cejie

This article considers the question of the importance of the Commentaries on the OECD Model and, in particular, whether an ambulatory or a static approach to changes in the OECD Commentaries should be adopted. The point of departure is international tax law, with an emphasis on the Swedish perspective. Recent case law from the Supreme Administrative Court is also considered.

ARTICLES

Qatar/Gulf Cooperation Council

Oil Price Fluctuations and the Need for Tax Policy Reform in Qatar
Mahmoud M. Abdellatif, Ashraf Galal Eid and Binh Tran-Nam
This article considers the implications for Qatar of fluctuating oil prices, the problems that this raises regarding the balance between reducing government expenditure and the adverse effect on growth, and the need to use tax policy to stabilize the economy and diversify revenue and develop a more comprehensive tax system.

International/European Union/OECD

Adapting Current International Taxation to New Business Models: Two Proposals for the European Union

Yariv Brauner and Pasquale Pistone

In this article, Yariv Brauner and Pasquale Pistone outline two solutions for the European Union to deal with the current problems facing international taxation: the virtual permanent establishment solution and the withholding tax solution.

International/United States/European Union/OECD

The Revolution in Automatic Exchange of Information: How Is the Information Used and What Are the Effects?

Lauri Finér and Antti Tokola

The effect of automatic exchange of information standards on cross-border tax evasion has attracted only limited attention from academics. This article responds to this by analysing how the OECD Common Reporting Standard and the US Foreign Account Tax Compliance Act affect tax evasion and, therefore, states and taxpayers.

International

The Plastic Bag Tax: International Trends

Sally-Ann Joseph

In this article, the author provides a review of the literature on plastic bag bans and taxation, and examines the experiences of four countries, supplementing the research with several studies of other jurisdictions. The resulting analysis provides guidance for policymakers considering a plastic bag tax or redefining their approach.

International/European Union/OECD

Permanent Establishment versus Fixed Establishment: The Same or Different?

Karoline Spies

In this article, the author systematically compares the concepts of “permanent establishment” with regard to direct taxation and “fixed establishment” in respect of EU VAT, and establishes similarities and differences between the two. Although both concepts serve comparable functions (namely the allocation of taxing rights between states), their definitions differ in detail, which may lead to practical difficulties.

European Union/OECD

Current Challenges for EU Controlled Foreign Company Rules

Gilles Van Hulle

This article focuses on the challenges presented by the controlled foreign company rules in articles 7 and 8 of the EU Anti-Tax Avoidance Directive, not purely from a technical standpoint, but also from the perspective of tax policy.

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION
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