March 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. 3 - 2018 of the Bulletin for International Taxation is now available online.

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Other relevant events and courses:

Symposium
4th IBFD Africa Tax Symposium
9-11 May 2018,
Mombasa, Kenya
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Course

Principles of Transfer Pricing
27-29 June 2018
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Number 3 - 2018 contains the following:
TAX TREATY MONITOR

International/OECD

The Relationship between the OECD Multilateral Instrument and Covered Tax Agreements: Multilateralism and the Interpretation of the MLI

Daniel W. Blum

In this article, the author examines the relationship between the OECD Multilateral Instrument and Covered Tax Agreements focussing on the interpretational issues that consequently arise: (1) the influence of the MLI on the interpretation of CTAs; and (2) the effect of CTAs on the interpretation of the MLI.

China (People’s Rep.)/OECD/United Nations

A Comparative Study of the “Royalties” Provisions in the Tax Treaties Concluded by China

Shimeng Lan

In this article, the author undertakes a comparative study of the “royalties” provisions in the tax treaties that China has concluded by way of a general examination of the various issues relating to “royalties” together with an examination of specific examples.

International/OECD

Profit Attribution to Permanent Establishments – A Tax Treaty Perspective on the “Single Taxpayer” Approach

Shee Boon Law

In this article, the author provides a tax treaty perspective on the OECD’s Additional Guidance on the Attribution of Profits to Permanent Establishments, Action 7 – 2017 Public Discussion Draft, observing that countries which continue to follow article 7 of the pre-2010 OECD Model and the current UN Model would likely not accept the “single taxpayer” approach of attributing zero or minimal profits to a permanent establishment.

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ARTICLES

International/OECD

Output Legitimacy Deficits and the Inclusive Framework of the OECD/G20 Base Erosion and Profit Shifting Initiative

Irma Johanna Mosquera Valderrama

In this article, the author considers output legitimacy deficits in the context of the Inclusive Framework of the OECD/G20 Base Erosion and Profit Shifting Initiative, with special emphasis on the issues and problems that this raises for developing countries.

Finland/Luxembourg/Netherlands/European Union

The Implementation of the Controlled Foreign Company Rules in the EU Anti-Tax Avoidance Directive in Finland, Luxembourg and the Netherlands – The Effects on the Holding Company Structures of Finnish Groups

Antti Tokola

In this article, the author considers the implications of the implementation of the controlled foreign company rules in the EU Anti-Tax Avoidance Directive (2016/1164) in Finland, Luxembourg and the Netherlands, with special emphasis on the effects regarding the holding company structures of Finnish groups.

India

India Transfer Pricing Round-Up for 2017

Sunny Kishore Bilaney

The author, in this article, analyses significant developments in Indian transfer pricing in 2017, including the rules relating to three-tier documentation, the revised safe harbour rules, key tax court rulings and progress in the Indian advance pricing agreement programme.

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International

Taxing Sugar-Sweetened Beverages: A Bittersweet Solution

Mike Hammer

In this article, the author examines special taxes on sugar-sweetened beverages, which jurisdictions around the world are implementing in response to the growing obesity pandemic.

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