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   November 2018  
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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. 11 - 2018 of the Bulletin for International Taxation is now available online.

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Number 11 - 2018 contains the following:
TAX TREATY CASE LAW MONITOR

Belgium/International

Payments for the Use of a Footballer’s Image Rights: A Belgian Court’s Interesting Endeavour at Treaty Qualification

Bob Michel

In this article, the author examines a recent decision by the Court of Appeal of Ghent (Belgium) regarding the qualification for tax treaty purposes of image rights payments derived by a non-resident professional football player, active in the Belgian first division.

ARTICLES

Argentina/Brazil/Chile/Colombia/Costa Rica/Mexico/Panama/Peru/Uruguay/OECD/

International

Multinational Enterprises, Transfer Pricing and Value Chain Analysis in Latin America Following the OECD/G20 Base Erosion and Profit Shifting Initiative

Steef Huibregtse, Sonia Catalina Muñoz Rodríguez, Belisa Severini and Alejandro Delgado Perea

In this article, the authors examine the implications of the proposals in relation to the OECD/G20 Base Erosion and Profit Shifting initiative for the transfer pricing practices of a number of Latin American countries, with special emphasis on value chain analysis.

Australia/United States

The Effect of Global Intangible Low-Taxed Income on US Investment in Australia

Anton Joseph

The author, in this article, considers the implications of the introduction of the concept of global intangible low-taxed income by the US Tax Cuts and Jobs Act of 2017, with its stated intention of encouraging companies to invest in the United States, for US investment in Australia.

International/European Union/United States

(Re)defining the Balance between Tax Transparency and Tax Privacy in Big Data Analytics

Gianluca Mazzoni

This article considers the implications of the collection and the use of Big Data as it may affect tax transparency, tax authorities and the rights of taxpayers.

International/European Union/OECD

The Scope of the Commission’s Digital Tax Proposals

Martti Nieminen

In this article, the author examines the European Commission’s proposals regarding the Digital Services Tax Directive and the Significant Digital Presence Directive, with special emphasis on the scope of the two Directives and their implications for the European Union as a whole, the Member States and non-EU countries.

International/OECD

(Mis)guided by the Value Creation Principle – Can New Concepts Solve Old Problems?

Aleksandra Bal

In this article, the author provides a critical evaluation of the current OECD and EU attempts to tax the digital economy, focusing on the concept of value creation and the role of users and data in creating value.

Available online only

Afghanistan

Taxation and the Business Environment in Afghanistan

Bilal Hassan

In this article, the author discusses taxation and the business environment in Afghanistan. In this context, he suggests policy and administrative measures to strengthen the tax regime so as to collect more tax revenue and to improve the business environment for investment in order to encourage economic growth.

Available online only

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