July 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. 7 - 2018 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

72nd Congress of the International Fiscal Association
2-6 September 2018,
Seoul, Republic of Korea
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Transfer Pricing and Substance Masterclass
31 October-2 November 2018
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Number 7 - 2018 contains the following:

Hybrid Entities and the OECD Model (2017): The End of the Road?

Christopher Bergedahl

This article considers the important amendments made to the OECD Model (2017) and the Commentaries on the OECD Model (2017), with special emphasis on the implications of the changes made to articles 1 (Persons covered) and 23 (Methods for elimination of double taxation).


Inheritance and Estate Taxes: Tax Treaties, Connecting Factors and Worldwide Liability

Andres Duran

In this article, the author considers how tax treaties deal with the variety of connecting factors used to establish a worldwide liability in relation to inheritance and estate taxes.


Nigeria’s International Tax Policy with Particular Focus on the Allocation of Taxing Rights

Chike Jude Emedosi

This article examines Nigeria’s international tax policy choice and its implications by scrutinizing Nigeria’s tax treaties and National Tax Policy statements. It concludes that Nigeria’s international tax policy tends towards capital export neutrality. Consequently, Nigeria is losing significant amounts of tax revenue and should change its policy choice.

New Zealand/International

The Relationship between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties: A New Zealand Case

Brian J. Arnold

This article discusses a recent New Zealand Court of Appeal case involving the relationship between New Zealand’s CFC rules and the tax sparing provision in the China-New Zealand Income Tax Treaty (1986). The Court rejected the taxpayer’s claim on the basis of a narrow, literal interpretation of the elimination of double taxation article of the treaty.


Mobility of Individuals after BEPS: The Persistent Conflict between Jurisdictions

Giorgio Beretta

In this article, the author discusses the different policies a jurisdiction can implement to address the cross-border mobility of individuals, illustrates the main defensive strategies adopted by the emigration country and relates them to the introduction of preferential tax regimes for inward expatriates by the immigration country.


Reputational Tax Risk Management in Alternative Investment Fund Structures

T.J.C. van Dongen

Reputational tax risk management is an important topic for multinational enterprises and is slowly gaining traction in the alternative investment industry. This article commences with a short consideration of the background to reputational tax risk management, followed by practical suggestions regarding reputational tax risk management in the alternative investment industry.

China (People's Rep.)

Tax Issues Relating to Qualified Foreign Institutional Investors: The Chinese Experience

Cui Xiaojing and Chen Jingxian

This article considers the issues that have arisen regarding tax administration and collection in respect of qualified foreign institutional investors (QFIIs), including the withholding tax obligations of listed companies, tax information asymmetry and the identification of taxpayer shareholdings. The authors conclude that the system for QFIIs requires further refinement.


Report of the Proceedings of the Eighth Assembly of the International Association of Tax Judges Held in Helsinki on 6 and 7 October 2017

Bob Michel

This report summarizes the proceedings of the Eighth Assembly of the International Association of Tax Judges, which was held in Helsinki on 6 and 7 October 2017.

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