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   October 2013  
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World Tax Journal
This free e-mail service informs you about the contents of the forthcoming edition of World Tax Journal.

Issue No. 3 - 2013 of the World Tax Journal is now available online.

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Number 3 - 2013 contains the following:
Editorial: The Long March of International Taxation
towards a Global Tax Legal Order
Pasquale Pistone
Profit Shifting and “Aggressive” Tax Planning by Multinational Firms:
Issues and Options for Reform
Clemens Fuest, Christoph Spengel, Katharina Finke, Jost H. Heckemeyer and
Hannah Nusser
This article discusses the issue of profit shifting and “aggressive” tax planning by
multinational firms. The article makes two contributions. First, it provides some
background information to the debate by giving a brief overview of existing empirical
studies on profit shifting and by describing arrangements for IP-based profit shifting
which are used by the companies currently accused of avoiding taxes. We then show that preventing this type of tax avoidance is, in principle, straightforward. Second, we argue that, in the short-term, policymakers should focus on extending withholding taxes in an internationally coordinated way. Other measures which are currently being discussed, in particular unilateral measures, like limitations on interest and license deduction, fundamental reforms of the international tax system and country-by-country reporting, are either economically harmful or need to be elaborated much further before their introduction can be considered.
Taxing Capital Income in Emerging Countries: Will FATCA Open
the Door?
Itai Grinberg
For many emerging and developing economies, it is exceedingly difficult to constrain residents from evading tax liability on income from capital, whether earned domestically or abroad. Meanwhile, an international regime for combatting offshore tax evasion is emerging, and the form of the new regime will be established during a narrow window of opportunity over the next few years. If a uniform, multilateral automatic information exchange system is established, it would improve emerging countries’ ability to tax the offshore accounts of their residents and, perhaps more importantly, their capacity to collect information about and tax domestic-source income from capital. In contrast, a fragmented automatic information exchange regime likely would not benefit countries outside the developed economies. Interestingly, the concerns of emerging and developing
economies regarding the contours of the new international regime substantially align with the concerns of multinational financial institutions. As a result, emerging countries may find that multinational financial institutions could be improbable allies in the battle over taxing offshore accounts. However, a governance structure for a uniform automatic information exchange regime that could be useful to emerging countries’ tax administrations will materialize only if the regime evolves along the line of international financial law, with the G-20 playing an agenda-setting role. This article explores the requisite governance structure and concludes by describing steps emerging countries may take in bilateral and multilateral settings to help create that structure.
Stamp, Seligman and the Drafting of the 1923 Experts’ Report on
Double Taxation
Sunita Jogarajan
In 1923, the League of Nations published the Report by the Experts on Double Taxation (“the Report”). The Report discusses the economic consequences of international double taxation, the general principles which govern international competence in taxation and the application of those principles for the avoidance of double taxation. While there is some question as to the extent of the impact of the Report on the development of bilateral tax treaties practically, there can be little doubt that the Report was a seminal work in the intellectual debate. Utilizing original archival research, this paper considers how the Report came to be produced in its final form. The chronological narrative highlights
the views of the individual authors, the considerations that influenced each one and the eventual compromises reflected in the Report. The paper finds that the authors were unable to ignore practical issues and the likely inertness of economic forces in formulating their final conclusions, despite their theoretical leanings.
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