October 2018  
BIT Preview IBFD, Your Portal to
Cross-Border Tax Expertise
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 - 2018 of the Bulletin for International Taxation is now available online.

Visit www.ibfd.org for more information about IBFD publications and services.

Archive | Subscribe to other Journal Previews

P.O. Box 20237
1000 HE Amsterdam
The Netherlands
Tel: 31-20-554 0176
Fax: 31-20-622 8658

Other publications and courses available on International Taxation:

IBFD-PwC Transfer Pricing Seminar: Mastering the IP Life Cycle - Grasping the Intangible
30 October 2018
Amsterdam, The Netherlands
> Read more


Current Issues in International Tax Planning
27 February - 1 March 2019
Amsterdam, The Netherlands
> Read more

Number 10 - 2018 contains the following:


Conceptual Aspects of Beneficial Ownership in the Context of Property Law

Saurabh Jain and John Prebble

This article argues that the dominion test cannot logically be transposed to conduit company cases from cases involving interposed entities, which act as agents or nominees. Agents and nominees do not possess dominion over income. They are obliged under property law to pass on income to third parties, namely their principals or mandators, whereas a conduit company has property rights over income by definition. That is, it possesses dominion over its income simply by virtue of being a corporation. It follows that, if dominion is used as a test for determining whether an interposed company is eligible for treaty benefits, it will always qualify regardless of whether it acts as a conduit.

International/European Union

Curbing Base Erosion via Withholding Taxes: The Case for a “Reverse Controlled Foreign Company” Approach

Guglielmo Maisto, Paolo Arginelli and Cesare Silvani

The authors, in this article, propose a “reverse controlled foreign company” withholding tax as a way to counter base erosion.

European Union

The Potential of a Standard Audit File – Tax in the European Union: A Chance for Coordinated VAT Administration?

Alicja Majdanska and Karol Dziwinski

In this article, the authors consider the potential for the introduction of a Standard Audit File – Tax in the European Union with regard to VAT, and specifically whether this would offer opportunities to counter fraud and improve tax administration.


High-Net-Worth Individuals: The Challenge for Tax Administrations, Financial Intelligence Units and Law Enforcement Agencies

Alicja Majdanska, Clement Migai and Marta Olowska

This article considers the challenges faced by tax administrations, financial intelligence units and law enforcement agencies worldwide in dealing with the taxation of high-net-worth individuals, with a special focus on the experience of Africa.


Australian Residence and Source Rules and the Implementation of the Multinational Anti-Avoidance Law and the Diverted Profits Tax

H. Khiem (Jonathan) Nguyen

This article reviews the Australian residence and source rules, analyses their limitations and identifies the problems arising from application of these rules. It also considers the rationale for, and the effects of, the introduction of the Multinational Anti-Avoidance Law in 2016 and the Diverted Profits Tax in 2017.

United States/International

What Non-US Investors Should Know about the New US Tax Law

Huanyu Ouyang and James G.S. Yang

This article discusses the effect of the US Tax Cuts and Jobs Act of 2017 on taxpayers with an emphasis on non-US investors. Specifically, it notes the reductions in various tax rates, the move from a worldwide tax system and to a territorial one and the introduction of anti-avoidance measures.


The Legal Framework of the Botswana Special Tax Zone: The SPEDU Region and Action 5 of the OECD/G20 Base Erosion and Profit Shifting Initiative

Ame Rebecca Masuku (née Chimbombi)

This article considers the implications of the Botswana Special Tax Zone (SEZ) Policy of 2010 and the Botswana SEZ Act of 2015 that provides the legal framework under which SEZs are established, developed and managed in the light of Action 5 of the OECD/G20 Base Erosion and Profit Shifting initiative.

Available online only.

Please consider the impact on the environment before printing this e-mail.