September 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. 9 - 2018 of the Bulletin for International Taxation is now available online.

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Other publications and courses available on International Taxation:

Conference

9th IBFD International Tax Conference
8 November 2018,

Beijing, China

> Read more



Course

International Tax, Legal and Commercial Aspects of Mergers & Acquisitions
28 - 30 November 2018
Amsterdam, The Netherlands
> Read more



Number 9 - 2018 contains the following:
TAX TREATY MONITOR

International/OECD

The Artificial Intelligence Tax Treaty Assistant: Decoding the Principal Purpose Test

Blazej Kuźniacki

In this article, the author explores and advocates the use of an artificial intelligence tax treaty assistant with regard to resolving issues and problems in respect of the principal purpose test as proposed in relation to the OECD/G20 Base Erosion and Profit Shifting initiative.

Switzerland/OECD

The Mutual Agreement Procedure: A Swiss Perspective on Aspects of Action 14 of the OECD/G20 Base Erosion and Profit Shifting Initiative

Jessica Salom and Pascal Duss

In this article, the authors consider aspects of the Minimum Standards and Best Practices regarding the mutual agreement procedures contained in the Final Report on Action 14 of the OECD/G20 Base Erosion and Profit Shifting initiative and put them in context with the Swiss law and practice in this field.

Available online only

Mexico/International

The Role of Prodecon, the Mexican Tax Ombudsman Agency, in Ensuring Taxpayer Access to Mutual Agreement Procedures

Diana Bernal and Edson Uribe

In this article, the authors examine the recent action of the Mexican Tax Ombudsman Agency, or Prodecon, with regard to ensuring that taxpayers have access to mutual agreement procedures in relation to tax treaties and the protection of the rights of taxpayers in general.

Available online only

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

Developments in China’s Treaty Policy: Where is the Dragon Heading?

Yi Long

This article examines China’s treaty policy by comparing treaties with different states and regions, effective and terminated treaties, and the three periods of Chinese policy. The author concludes that policy is consistent with the growth of the Chinese economy in moving from a capital-importing to a capital-exporting country.

Available online only

TAX TREATY CASE LAW MONITOR

Australia/International

Rethinking the Interest Deduction Rules in Light of the Chevron Australia Case

Kerrie Sadiq

Based on the case of Chevron Australia (2017), this article argues that excessive debt loading and the transfer mispricing of financial transactions could be addressed by a limited formulary apportionment rule for debt deductions. The article also offers insights into the likely implications of the global adoption of such a model.

ARTICLES

International/OECD/European Union

Business Restructurings: Options and Practice – Part 2

René Offermanns and Rita Botelho Moniz

Part 2 of this article examines the evolution of the OECD Transfer Pricing Guidelines over the years that resulted in the new 2017 edition, and the existing regional and local specific regulations affecting business restructurings. The article uses two case studies to illustrate the issues that arise regarding such restructurings.

Australia/Portugal/Spain/Switzerland

Can Special Attraction Regimes Lead to Treaty Residence?

Sergio I. Mutis

This article analyses if it is possible for individuals under special attraction regimes to be considered residents of a Contracting State under Article 4 of the OECD Model (2014). For this purpose, the regimes enacted by Australia, Portugal, Switzerland and Spain, as well as some of their tax treaties, are briefly examined.

Available online only

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION