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Issue No. 4/5 - 2018 of the Bulletin for International Taxation is now available online.

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Conference
72nd Congress of the International Fiscal Association
2-6 September 2018
Seoul, Republic of Korea
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Current Issues in International Tax Planning
22-24 October 2018
Amsterdam, The Netherlands
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Number 4/5 - 2018 contains the following:

INTERNATIONAL TAX POLICY IN A DISRUPTIVE ENVIRONMENT:

A SPECIAL ISSUE

ARTICLES

International/OECD

Foreword: International Tax Policy in a Disruptive Environment

Allison Christians, Wolfgang Schön and Stephen E. Shay

In this foreword to International Tax Policy in a Disruptive Environment: A Special Issue, the authors provide an overview of the two-day interdisciplinary conference that took place in Munich on 14-15 December 2017, and offer a synopsis of the articles in this special edition of the Bulletin for International Taxation.

International/OECD

Value Creation: A Standard in Search of a Process

Susan C. Morse

This article explores the idea of value creation. It imagines a worldwide dispute resolution forum and considers existing processes for developing the meaning of value creation, including OECD planning, unilateral national action and competent authority and arbitration treaty procedures. It predicts how interested parties will influence the meaning of value creation.

International/OECD

“Taxation Where Value is Created” and the OECD/G20 Base Erosion and Profit Shifting Initiative

Johanna Hey

This article examines the concept of “taxation where value is created” and its role as a potential solution to the issues raised with regard to the OECD/G20 Base Erosion and Profit Shifting initiative.

International/OECD

Country-by-Country Reporting and the International Allocation of Taxing Rights

Michelle Hanlon

In this article, the author examines the OECD/BEPS country-by-country reporting (CbCR) requirements and the disconnect between CbCR data and the arm’s length principle, discusses the potential benefits and costs of country-by-country data, and concludes by considering the possible implications of CbCR for the international allocation of taxing rights.

International/OECD

Country-by-Country Reporting and the International Allocation of Taxing Rights: Comments to Michelle Hanlon

Christoph Spengel

In this article, the author comments on Michelle Hanlon's article on the OECD’s country-by-country reporting requirements and the disconnect between country-by-country reporting data and current tax policy with regard to the arm’s length principle.

International/OECD

Competition, Coordination and Avoidance in International Taxation

Michael Keen

This article examines the links between competition, coordination and avoidance in international taxation through the lens of simple economic ideas, reviews the relationship between competition and coordination and considers the impact on tax competition of measures to reduce tax avoidance, with a focus on the issue of preferential regimes.

International/OECD

The OECD Inclusive Framework

Allison Christians and Laurens van Apeldoorn

This article considers the various issues and implications raised by the OECD’s Inclusive Framework and how this affects both OECD member countries and non-member states.

International/OECD

The Impact of the BEPS Multilateral Instrument on International Tax Policies

Johann Hattingh

This article assesses the impact of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting by analysing the preliminary reservations of signatory countries, while offering some speculative points about the influence of the MLI on international tax policies and the OECD Model.

International/OECD

Goodbye to All That? A Requiem for the Destination-Based Cash Flow Tax

Daniel Shaviro

In this article, the author addresses the destination-based cash flow tax, which was recently proposed as a tax reform option in the United States, compares it to its forebears, the flat tax and the X-tax, and concludes that although its substance has potential merit, it does not warrant further consideration in tax policy debate.

International/OECD

Sales-Based Apportionment of Profits

Ulrich Schreiber

The author, in this article, considers the sales-based apportionment of profits in the context of, and as a response to the issues raised by, the OECD Base Erosion and Profit Shifting Project.

International/OECD

An Inverted Image Inspires a Question: Comments on Professor Ulrich Schreiber’s “Sales-Based Apportionment of Profits”

J. Scott Wilkie

In this article, the author offers some observations in response to Professor Schreiber’s proposal for the apportionment of business profits earned by multinational enterprises and concludes with a question: Why not a minimum tax possibly configured as a withholding tax?

International/OECD

Ten Questions about Why and How to Tax the Digitalized Economy

Wolfgang Schön

In this article, the author raises major policy questions with regard to current OECD and EU projects which aim at the taxation of the digitalized economy. He lays out the basic choice between tax measures securing one-time taxation of profits and a full shift of taxing rights towards market countries, and he presents options including dedicated new taxes on digital transactions, a realignment of source rules or (preliminary) withholding taxes. He concludes that the currently discussed new set of rules based on the notion of “digital presence” seems less in line with the traditional understanding of the corporate tax than a set of rules based on the notion of “digital investment”.

International/OECD

A US Subnational Perspective on the “Logic” of Taxing Income on a “Market” Basis

Walter Hellerstein

In this article, the author comments on some of the fundamental propositions advanced by Wolfgang Schön’s examination of “Ten Questions about Why and How to Tax the Digitalized Economy”.

International/OECD

Redistribution between Rich and Poor Countries

Miranda Stewart

In this article, the author considers the issue of the redistribution of wealth from richer to poorer countries and the role that taxation could play in such a scenario.

International/OECD

Comment on Miranda Stewart’s “Redistribution between Rich and Poor Countries”

Itai Grinberg

This article is a response to the article written by Miranda Stewart regarding the issue of the redistribution of wealth from richer to poorer countries and the role that taxation could play in such a scenario.

International/OECD

Transfer Pricing Regimes for Developing Countries

Patricia Hofmann and Nadine Riedel

The authors, in this article, consider transfer pricing regimes as they could be adopted and adapted by developing countries in response to the various related issues raised by the OECD/G20 Base Erosion and Profit Shifting initiative.

International/OECD

The Impact of the OECD/G20 Base Erosion and Profit Shifting Project on the Task for Developing Countries of Applying the Arm’s Length Principle in Practice

Richard S. Collier

This article considers the practical implications of the OECD/G20 Base Erosion and Profit Shifting project regarding the application of the arm’s length principle by developing countries.

International/OECD

Offshore Transfers: Policies and Divergent Views

Mitchell A. Kane

This article considers the effort of jurisdictions to tax the gain of foreign persons resulting from offshore asset sales, examines the range of approaches taken by OECD and non-OECD countries, explores some of the basic underlying policy considerations, and demonstrates several reasons why developing countries might consider a more expansive approach.

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