August 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. 8 - 2018 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

Conference
IBFD Dialogues on International Taxation Seminar
3 September 2018, Seoul, Republic of Korea

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Course
Transfer Pricing and Substance Masterclass
31  October - 2 November 2018
Amsterdam, The Netherlands
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Number 8 - 2018 contains the following:
ARTICLES

International/OECD

The China-Pakistan Avoidance of Double Taxation Agreement and the China-Pakistan Economic Corridor

Muhammad Ashfaq Ahmed, Na Li and Peter Mellor

In this article, the authors review the principal features of the China-Pakistan tax treaty and its impact on the China-Pakistan Economic Corridor project.

United States/OECD

The Effect of the FATCA Withholding Tax on US Investment Abroad

Johan Hagelin

This article is based on a study of the effects of the Foreign Account Tax Compliance Act (FATCA) on US investment abroad. It provides evidence suggesting the possibility of a positive correlation between FATCA participation and US investment abroad due to the withholding tax on payments to foreign financial institutions in non-participating jurisdictions.

International/OECD

Historical Introduction to the Test of Dominion in the Context of Double Tax Treaties

Saurabh Jain and John Prebble

The term “dominion” represents the right to decide how to use income or property. Courts have considered the presence of dominion to conclusively indicate that an interposed company is the beneficial owner and therefore entitled to treaty benefits. This article analyses from a historical perspective how dominion developed as a test in conduit company cases.

International/OECD/European Union

Business Restructurings: Options and Practice – Part 1

René Offermanns and Rita Botelho Moniz

Part 1 of this article considers current common options for business restructurings, which give rise to various notable cases that are frequently in the news. The article draws on practical experience to understand the purpose, consequences and most important considerations to bear in mind when restructuring a business.

European Union/OECD

The Anti-Tax Avoidance Directive 2 and Hybrid Financial Instruments: Countering Deduction and Non-Inclusion Schemes in Third-Country Situations

Ramon Tomazela Santos

This article analyses the second Anti-Tax Avoidance Directive and its role in countering deduction and non-inclusion schemes caused by the use of hybrid financial instruments in third-country situations, in the light of primary EU law and Action 2 of the OECD/G20 Base Erosion and Profit Shifting initiative and its underlying justifications.

Pakistan

The Taxation of Non-Profit Organizations in Pakistan

Bilal Hassan

This article discusses and evaluates tax provisions of the Income Tax Ordinance 2001 and the Income Tax Rules 2002 that govern the taxation of non-profit organizations in Pakistan.

Available online only

Greece

The Tax Treatment of Foreign Trusts and Foundations in Greece: Administrative Guidance Clarifies an “Opaque” Situation

Lydia-Elisavet Sofrona

The author, in this article, examines the tax treatment of foreign trusts and foundations in Greece in light of the recent administrative guidance that the tax administration provided on this matter, including the application of tax treaties to such trusts and foundations, together with consideration of relevant procedural issues.

Available online only

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