December 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. 12 - 2018 of the Bulletin for International Taxation is now available online.

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Number 12 - 2018 contains the following:
ARTICLES

United States/European Union/International

Should We Use Value Creation or Destination as a Basis for Taxing Digital Businesses? – Krister Andersson’s Comments on the 2018 Klaus Vogel Lecture Given by Professor Michael Devereux

Krister Andersson

Krister Andersson, in this article, provides his thoughts regarding Professor Michael Devereux’s 2018 Klaus Vogel Lecture on the topic of “Should We Use Value Creation or Destination as a Basis for Taxing Digital Businesses?”.

International/OECD

The OECD International Compliance Assurance Programme: Just a New Multilateral and Cooperative Model of Tax Control for Multinational Enterprises?

Jose M. Calderón

This article examines the OECD’s International Compliance Assurance Programme and considers whether it constitutes just a new model for tax control in relation to multinational enterprises or whether it could also be considered the basis of an unprecedented dispute-prevention mechanism that can reduce the level of transfer pricing controversies and stabilize the post-BEPS framework.

International/OECD

The OECD/G20 Base Erosion and Profit Shifting Initiative and Developing Countries

Richard Collier and Nadine Riedel

This article considers the implications of the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative by reference to the priorities of developing countries. It also suggests ways in which the Project could be made a better fit for the needs of such countries.

Argentina/Brazil/Chile/Colombia/Costa

Rica/El Salvador/Guatemala/Mexico/

Panama/Peru/Uruguay

Slicing the Pie in Latin America – A Pragmatic Approach to a Value Chain Analysis

Steef Huibregtse and Sonia Catalina Muñoz Rodríguez

This article considers the use of a value chain analysis in a Latin American context, with an emphasis on the adoption of a pragmatic approach to the use of this technique with regard to transfer pricing issues.

China (People’s Rep.)/ ASEAN/ International/OECD

Improved Tax Dispute Resolution between China and the ASEAN Countries under the Belt and Road Initiative

Diheng Xu

China has established the Belt and Road Initiative International Commercial Court-Connected and Mediation Centre, which is intended to resolve commercial disputes between China and the ASEAN countries. In this article, the author analyses the advantages and disadvantages of this action, and suggests ways of improving the mechanism.

Nigeria/OECD

A Review of the Nigerian Country-by-Country Reporting Regulations

Victor Adegite

The author, in this article, examines the Nigerian Regulations on country-by-country reports, taking into account the implications for taxation in Nigeria and internationally.

Available online only

International/OECD

Beneficial Ownership and the Contractual Obligation of an Interposed Company to Pass On Income

Saurabh Jain and John Prebble

This article argues that an interposed company may be under a contractual obligation to pass on income to a resident of a third state. Such a company would still possess dominion over the income. However, the absence of such an obligation is inconclusive for determining whether an interposed company is a conduit.

Available online only

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