April 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. 4a - 2018 of the Bulletin for International Taxation is now available online.

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4th IBFD Africa Tax Symposium
9-11 May 2018,
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Principles of Transfer Pricing
27-29 June 2018
Kuala Lumpur, Malaysia
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Number 4a - 2018 contains the following:



Available online only


United Kingdom/European Union

Managing EU VAT Risks for Platform Business Models

Aleksandra Bal

The popularity of the platform business model is on the rise. Six of the ten most valuable companies in the world derive much of their value from their multisided platforms. This article examines platforms as business models and outlines some of the major indirect tax risks which platform operators are exposed to in the European Union.


Japanese Tax Reforms Square Up to BEPS Action 1 to Tackle Tax Challenges of the Growing Digital Economy

Adam Becker

In this article, the author focuses on Japan’s response to the tax challenges of the growing digital economy, including the country’s significant reforms in respect of the definition of permanent establishment, the application of consumption tax rules and the reach of anti-tax haven rules to controlled foreign corporations of Japanese-headquartered MNEs.


Some Comments on the Attribution of Profits to the Digital Permanent Establishment

Yariv Brauner and Pasquale Pistone

In the authors’ view, the concept of digital permanent establishment (PE) is the preferable solution to tackle the challenges of the digital economy. In this article, the authors comment on the attribution of profits to digital PEs.


The Future of the Permanent Establishment Concept

Vishesh Dhuldhoya

In this article, the author evaluates whether the amendments proposed by the OECD/G20 BEPS Initiative effect the permanent establishment threshold to become economic in nature rather than one based on physical presence. In doing so, the author considers the future of the permanent establishment concept.


Addressing the Tax Challenges of the Digitalization of the Economy – A Possible Answer in the Proper Application of the Transfer Pricing Rules?

Raffaele Petruzzi and Svitlana Buriak

In this article, the authors advance a possible solution to the challenges posed to international taxation by the digitalization of the worldwide economy. They argue that the proper application of the transfer pricing rules solves a problem of profits attribution to all the jurisdictions where digitalized companies generate their value.


Taxation of Cloud Computing in Brazil: Legal and Judicial Uncertainties

Tathiane Piscitelli and Doris Canen

In this article, the authors examine the legal and judicial scenario regarding taxation of cloud computing in Brazil, emphasizing disputes concerning taxation at the federal, state and municipal levels, as well as general legal uncertainty arising from these disputes.


Recent Developments in Brazil Regarding the Indirect Taxation of Services in the Digital Economy

Marciano Seabra de Godoi

This article considers Brazilian indirect taxation, examines recent legal initiatives through which municipalities and states have disputed the tax basis of digital economic activities, and criticizes the Brazilian judicial system’s inability to timely settle tax disputes in a legal system where nearly all tax measures sooner or later become constitutional.

Australia/United Kingdom/International/OECD

An Analysis of “Google Taxes” in the Context of Action 7 of the OECD/G20 Base Erosion and Profit Shifting Initiative

Yasin Uslu

In this article, the author considers the influence of “Google Taxes” in relation to Action 7 of the OECD Base Erosion and Profit Shifting initiative regarding the prevention of the artificial avoidance of the status of a permanent establishment.


Digital Revolution. Tax Revolution?

Piergiorgio Valente

This article considers key questions regarding the Digital Revolution and its implications for taxation, including what the necessary link for a jurisdiction to tax corporate income is in the absence of a physical presence and how the value derived from data analysis should be apportioned between jurisdictions for tax purposes.


Australia/Hungary/India/Italy/United Kingdom/International/European Union/OECD

Finding Middle Ground Over Unilateral Digital Taxation

Nana Ama Sarfo

In this article, the author discusses how unilateral solutions to digital taxation may inform the broader, global discussion about the digital economy.

International/European Union/OECD

Taxation of the Sharing Economy: Recurring Issues

Carrie Brandon Elliot

In this article, the author reviews the recurring issues surrounding direct and indirect taxation of the sharing economy, including obstacles to compliance and collection.


Introduction: A Stress-Test for the International Consensus

Robert Goulder

In this article, the author provides an overview of the tax challenges presented by the digital economy.

United States

Taxing the New Gig Economy

Ajay Gupta

In this article, the author examines the implications of taxing the fast-emerging “gig” economy, characterized by networked peer production of services.


A Review of Comments on the Tax Challenges of the Digital Economy

Barry Larking

In this article, the author examines the comments received by the OECD on action 1 of the base erosion and profit-shifting project regarding the tax challenges of the digital economy.


Argentina’s Journey to a Digital VAT

Jimena Milessi

In this article, the author examines Argentina’s efforts to tax non-resident digital companies.


Permanent Establishment and the Digital Economy

Marie Sapirie

In this article, the author discusses the challenges of fixing the problems with permanent establishment or finding a new concept that works satisfactorily in the digital age.

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