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We bring you the latest industry news and expert analysis on the hottest developments in international taxation.


IBFD Tax Takes: News & Views

IBFD’s video series Tax Takes: News & Views provides our worldwide tax community with the latest key news and insights. First up will be the week’s top news, selected from IBFD’s market-leading Tax News Service, followed by an interview on a current hot or emerging topic with a leading tax expert.




Episode: Global Tax Reform: Is OECD the Only Game in Town?


The views: Is the OECD’s BEPS Project still on course, or has it veered away from its original intent to reduce profit shifting? Michael Devereux (Director, Oxford University Centre for Business Taxation) and Stuart Gibson (Chief Editor, Global News and US, IBFD) discuss alternative approaches to tackle the BEPS Project’s current challenges.

The news: This week’s episode kicks off with news on:

  • Colombian court blocks COVID-19 relief while other countries step up efforts 
  • Canada targets online platforms while Estonia shelves its plans
  • Gibraltar starts losing EU tax benefits 

Previous episodes of IBFD Tax Takes: News & Views

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Talking Points

Talking Points is a brand-new service that provide IBFD users with market-leading commentary and analysis on the latest and hottest developments in international taxation. 

Talking Points showcase thought leadership from around the world on key developments, news items and other important international tax topics. IBFD readers will benefit from valuable insights, reasoning, opinions and viewpoints putting tax developments in perspective from some of the most prominent leaders in international taxation.

This series of papers aims to enlighten the international tax community on matters of significant interest. Although all relevant aspects were critically analysed, your feedback is always welcome.

Monthly Talking Points articles are available to subscribers with Tax News Service (TNS) access. 

To view one of IBFD's free Talking Points papers on the IBFD Tax Research Platform (TRP), click on the links below.

Latest Free Talking Points 

Ukraine - The Impact of War on Tax Policy – Lessons from Ukraine

Russia’s military invasion of Ukraine has demanded urgent changes to Ukrainian tax policy, resulting in the adoption of over 20 tax-related laws since the war began in February 2022. The parliament has prioritized measures that ease the tax burden on businesses, whose trade has faced unprecedented challenges. Tetyana Zhuravska’s article discusses some of the lessons learned, points out the crucial wartime tax policy developments and comments on further proposals.

Tetyana Zhuravska, Associate at Baker McKenzie Kyiv, Ukraine.

Tetyana Zhuravska is an associate at Baker McKenzie Kyiv, Ukraine. She has more than 7 years of experience in domestic and international tax planning, tax dispute resolution and transfer pricing. She specializes in cross-border tax matters, including international tax disputes. Tetyana is admitted to the Bar in Ukraine and holds a Master’s in International Tax Law from King's College London. She can be reached through her LinkedIn profile.




Free Talking Points currently available

European Union - Will the European Union Fall in Love with DEBRA?

The European Commission has proposed a new directive to more closely equalize the income tax treatment between equity and debt financing for corporations doing business in EU Member States. Carla Valério examines the details of the proposal – with the clever acronym DEBRA – and looks at what it could mean for European corporations and capital markets, if adopted.

View this Talking Points article


How Will the World Finally COP to the Realities of Pricing Carbon?

Carbon pricing was high on the agenda at last year’s United Nations Climate Change Conference, known as COP26. Rafael Barbosa de Sousa explains what tax professionals need to know about carbon pricing and carbon taxation, and cautions policymakers to carefully consider all the consequences – intended and unintended – before enacting carbon taxes.

View this Talking Points article


Crossing the Digital Services Tax Divide – But Is It Worth the Journey? by George L. Salis

Despite compelling legal and constitutional barriers to digital services taxes (DSTs) in the United States, more states are moving forward with EU-style DST taxing models in the post-COVID economy. How did we get here, and what do tax professionals need to know about this growing trend?

View this Talking Points article


United States/OECD/International - Will Democrats Fall into Their Own Trap on Pillar Two? by Alex M. Parker

The Biden administration touted the OECD’s July announcement of a global agreement on the Pillar Two minimum tax as a major foreign policy achievement, which it was. Alex M. Parker examines how Congressional Democrats’ efforts to enact a US domestic minimum tax at odds with Pillar Two may backfire.

View this Talking Points article



White Papers


GTTC Universities Project 2020: Treaty policy of/with developing countries 

This is the fourth publication of the finalist papers of our GTTC Universities Project’s annual competition, part of the IBFD Global Tax Treaty Commentaries (GTTC) Project. The concept of the competition is to have university student teams extract specific and relevant data concerning tax treaties and process them under the guidance of their mentors.

View this White Paper


The Third Edition of the GTTC University Project: “The Impact of the MLI on Countries’ Tax Treaty Policy”

This is the third publication of the finalist papers of our GTTC Universities Project’s annual competition, part of the IBFD Global Tax Treaty Commentaries (GTTC) Project. The concept of the competition is to have university students’ teams extract specific and relevant data concerning tax treaties and process them under the guidance of their mentors.

View this White Paper


Empirical Evidence in Tax Treaties: In Search for the ‘Hidden Tax Treaty Model

This is the second publication of the finalist papers of our GTTC Universities Project’s annual competition, part of the IBFD Global Tax Treaty Commentaries (GTTC) Project. The concept of the competition is to have university students’ teams extract specific and relevant data concerning tax treaties and process them under the guidance of their mentors.

View this White Paper




Brexit Tax Implications – State of Play upon Entry into Force of Withdrawal Agreement

This White Paper describes the state of play upon the entry into force of the Withdrawal Agreement with regard to selected Brexit tax implications. View this White Paper


VAT Aspect of Chain Transactions – Cutting the Gordian Knot

This paper discusses article 36a, 1 which is a new provision of the VAT Directive that is to be transposed by EU Member States effective January 2020. Article 36a aims to simplify the taxation of chain transactions.View this White Paper


State Aid – Gibraltar’s Tax Exemption on Interest and Royalties and its Tax Ruling Practice

The Commission has determined that Gibraltar’s tax exemption regime for passive interest and royalties between 2011 and 2013 selectively favoured certain multinational companies in breach of State aid rules (article 107 of the TFEU). Furthermore, the Commission found that five tax rulings issued by Gibraltar during the same period constituted State aid. This paper provides the background, the facts and the line of reasoning, and it concludes with the implications of the Commission’s decision. View this White Paper


Brave New World: Automation, Unemployment and Robot Taxes

In this White Paper, the author discusses the potential threat to jobs posed by increased automation and describes some recent responses, including robot taxes and universal basic income. View this White Paper


UK CFC Group Financing Exemption – State Aid as a Tool to Secure a Fair Share of Tax

According to the Commission’s final decision in State aid scheme UK CFC Group Financing Exemption, the group financing exemption included in the UK CFC rules does not constitute illegal State aid in cases where financing income relates to UK-connected capital. However, the group financing income is not justified and constitutes illegal State aid when the financing income derives from UK activities. This paper provides the background, the facts and the Commission’s findings, and concludes with comments on the case. View this White Paper


Customs Value and VAT Base – A Match Made in Heaven?

With the growth of global trade, levies on the cross-border movement of goods have become an increasingly important source of state revenue. To determine the amount of such levies, correctly establishing the base is crucial, and since customs value affects not only the amount of payable customs duty but also the amount of import VAT, the interaction between the customs value and VAT base raises many questions. This paper focuses on some of the questions dealt with in European case law. View this White Paper


A Snapshot of the African Continental Free Trade Area (AfCFTA)

In this White Paper, the author generally describes the essence of the African Continental Free Trade Area (AfCFTA), briefly highlighting its main objectives and ambit, explaining its institutional framework and discussing the magnitude of its interaction with Regional Economic Communities (RECs) and the World Trade Organization (WTO), among others. View this White Paper


Remedy for Tyranny: Statehood as a Solution to Taxation without Representation in Washington, DC

The author addresses the issue of taxation without representation as it pertains to residents of the US capital and discusses recent legislation proposing statehood as a possible solution. View this White Paper


Incorrect system of reference: ECJ overrules Commission decision on German restructuring clause

The Court of Justice of the European Union (ECJ) recently overruled a decision of the European Commission that had found the restructuring clause in section 8c(1a) of the German Corporate Income Tax Act (CITA) to infringe EU State aid rules. The ECJ found that the Commission used an incorrect system of reference when it determined the selectivity of the rule in question. This paper provides background information, insights into the findings of the Commission, the General Court and the ECJ, and related comments. View this White Paper


Latvia: Individual Income Tax Rules for Virtual Currency Transactions

The author provides a brief outline of Latvia’s existing regulatory framework and discusses the proposed individual income tax rules for virtual currency transactions in Latvia. View this White Paper


BEPS in Latin America (Part II): A review of the implementation of Actions 2, 3, 4 and 12

This White Paper is a follow-up of the White Paper “BEPS in Latin America (Part I): A review of the implementation of minimum standards and the peer review process” and reviews the progress made by Latin American countries that have joined the Inclusive Framework in respect of the implementation of the OECD Base Erosion and Profit Shifting (BEPS) Actions 2, 3, 4 and 12. View this White Paper


McDonald’s – Limits on State Aid Control in Tax Ruling Investigations

According to the recent Commission decision in regard to McDonald’s, the tax rulings issued by Luxembourg in 2009 and allowing the non-taxation of McD Europe’s profits in Luxembourg, even when such profits were not taxed elsewhere (in particular in the United States), are in line with national law and the Luxembourg-United States Income and Capital Tax Treaty (1996) and therefore do not infringe EU State aid rules. The Commission found that the double non-taxation in the McDonald’s case is the result of a mismatch between the Luxembourg and the US tax laws and does not derive from a special treatment granted by Luxembourg. This paper provides the background, the facts and the Commission’s findings, and presents some follow-ups to the investigation. View this White Paper


Closing the VAT Gap

The VAT gap exists due to the defects of the current VAT system, these imperfections leading to a decrease in collected tax revenues. There are several remedies, some of which are controversial. In this regard, the annual VAT gap reports reflect the progress towards making a robust VAT system. View this White Paper


Tax Ghosts: Spectres of the Shadow Economy

Tax ghosts, those dispiriting spooks of the fiscal system, are persistent spectres in the shadow economy. In this White Paper, the author describes various types of tax ghosts, discusses their impact, outlines current ghostbusting strategies and reviews the OECD’s recent recommendations for further work. View this White Paper


Taxing Social Media Income – The Dutch Perspective

In this White Paper, the authors explain how social media content creators (bloggers, vloggers and YouTubers) earn money and outline potential consequences of social media activities under the Dutch income tax. View this White Paper


VAT and Holding Companies’ Involvement: Benefit of the Doubt?

On 5 July 2018, the ECJ ruled in its judgment in the case of Marle Participations (C-320/17) that a holding company's involvement in the management of its subsidiary should be defined as all transactions constituting an economic activity performed by a holding company for the benefit of its subsidiary. Although this judgment seems to provide guidance on when a holding company can be regarded as a VAT taxable person, whereby such a company is thus in principle able to deduct input VAT, this White Paper raises some questions as to whether this judgment really does provide guidance or whether it results in even more questions. View this White Paper


European Commission – negative State aid decision with recovery in ENGIE

According to the Commission’s final decision in regard to Engie, two tax rulings issued by Luxembourg endorsed a domestic hybrid mismatch arrangement (i.e. the treatment of the same transaction as both debt and equity) leading to double non-taxation and, accordingly, granted to the beneficiary (Engie) a selective advantage resulting in incompatible State aid contrary to article 107 TFEU. This paper provides the background, briefly presents the facts and the line of reasoning and includes some follow-ups and comments. View this White Paper


Tax Simplification: It’s Complicated

Tax codes are notoriously complex and, despite frequent calls for simplification, there seems to be no simple solution. In this White Paper, the author highlights the complexity of the US tax code, examines its causes and concludes that some complexity is unavoidable to ensure a comprehensive and fair tax system. View this White Paper


South Dakota v. Wayfair - The Global Impact

On 21 June 2018, the US Supreme Court issued its highly anticipated decision in South Dakota v. Wayfair. The case was called the “tax case of the millennium” given its huge impact on the sales taxation of electronic commerce in the United States. This White Paper describes the Supreme Court’s decision, explains its impact on non-US businesses and puts the decision in the context of the current debate on the taxation of the digital economy. View this White Paper


MLI – Its Entry into Force and the Consolidated Texts of Impacted Articles of the First Affected Treaties

In this White Paper, the authors present all changes affecting these treaties and include as annexes the consolidated texts of the relevant provisions, with modifications and supplements made by the MLI visibly incorporated. View this White Paper


Taxation of the Digital Economy – the EU’s outlook

In this paper, the authors describe and comment on the European Commission’s two proposals for taxation of digital activities in the European Union and its recommendation to Member States on amending their tax treaties with third countries. View this White Paper


Tax-Related Identity Theft

In this paper, the author describes tax-related identity theft, references recent cases of the crime, offers prevention recommendations and outlines the prescribed procedure for victims. View this White Paper


Does the Tax Sector Need Blockchain?

Blockchain is frequently praised as a technological innovation that can be the panacea for all of the world's problems. In this paper, the author critically examines the usefulness of blockchain technology in the tax sector. View this White Paper


Halfway towards Consensus or Chaos? Taxation of the digital economy at the crossroads

On 16 March 2018, the OECD presented its long-awaited interim report of the tax challenges arising from digitalization. The OECD stated that there is no consensus among countries on whether and to what extent changes to the current tax regime are needed; however, an agreement should be reached by 2020. In this White Paper, the author provides some comments on the recently issued interim report. View this White Paper


Implementing the OECD/G20 BEPS Package in Developing Countries — An assessment of the priorities, experiences, challenges and needs of developing countries

This White Paper announces a report that IBFD prepared for the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) as part of its research and advisory work for the German Federal Ministry for Economic Cooperation and Development (BMZ). The aim of the report is to identify the priorities, experiences, challenges and needs of developing countries when implementing BEPS recommendations, specifically partner countries of German Development Cooperation (GDC), in order to assess where capacity building assistance is most needed. The report is divided in two main parts – a desk study and a survey study. The survey targeted GDC partner countries and was conducted in July and September 2017. View this White Paper


Definitive system of reduced VAT rates – Too much freedom?

The recent proposal of the European Commission would greatly liberalize the system of reduced VAT rates. Although this approach is in line with the planned definitive VAT system, there are still questions of both a political and technical nature that need to be considered during future consultations. View this White Paper


Revenue Losses due to VAT Gaps – A Study of Selected African Countries

This White Paper seeks to identify some of the causes of the VAT gap and proposes tools to ameliorate the VAT gap. View this White Paper


BEPS in Latin America (Part I): A review of the implementation of minimum standards and the peer review process

This White Paper reviews the progress made by Latin American countries that have joined the Inclusive Framework in respect of the implementation of the BEPS minimum standards and the status of the peer review process they are subject to. View this White Paper


Corporate Income Tax Reform in Latvia

The author provides a brief outline and analysis of the corporate income tax (CIT) reform in Latvia. The new CIT Law follows the Estonian CIT system, where CIT is paid on distributed profits. The classical system is abolished. View this White Paper


Major Tax Developments of 2017

This White Paper summarizes some of the major tax developments of 2017. The authors discuss, among others, the US tax reform, the Brexit progress, the Paradise Papers, the Multilateral Instrument and the EU blacklist of non-cooperative jurisdictions. View this White Paper


Prospects for a post-Brexit customs cooperation

This paper examines the vision of the United Kingdom and of the European Union in their respective approaches to the United Kingdom’s withdrawal from the Customs Union. View this White Paper


New Chinese Rules on Special Tax Investigation Adjustments and Mutual Agreement Procedures

This White Paper reviews the recently released SAT Announcement [2017] on special tax adjustments and mutual agreement procedures. View this White Paper


Will Trump’s Tax Reform Make America Great Again?

On 26 April 2017, the White House unveiled the core principles of Trump’s tax reform, which is meant to be “one of the biggest tax cuts in American history” and “the most significant tax reform since 1986”. This White Paper explains and comments on the reform proposal. View this White Paper


OECD Multilateral Convention: Flexibility versus the BEPS Project

The release of the OECD Multilateral Convention has revealed that states may decide to disregard many treaty-related measures of the OECD/G20 BEPS Project despite being signatories to it. This paper will look at the reasons behind such an astonishing degree of flexibility, not only in regard to the potential effectiveness of the Multilateral Convention but also in regard to its underlying objectives.

The text of the OECD Multilateral Convention (2016) is available and searchable on the IBFD Tax Research Platform. View this White Paper


Trump’s Tax Plan

In this paper, the author provides a brief outline and analysis of Trump’s tax plan and draws comparisons with the tax plan proposed by House Republicans.
With the inauguration of President-elect Donald J. Trump at hand, there is considerable interest in and apprehension about his innumerable campaign promises. For this paper, the author limits his focus to Trump’s tax-related proposals, which include a reduction of the corporate income tax rate and a consolidation of the individual income tax brackets. View this White Paper


US Treasury Department expresses concerns with European Commission’s State aid investigations

This white paper outlines the main concerns that the US Treasury Department has expressed with regard to the European Commission’s new approach in its State aid investigations of transfer pricing rulings issued by EU Member States. View this White Paper


Tax Rulings and State Aid Investigations: The Apple Case

Since June 2013, the European Commission has been investigating the compatibility of tax rulings granted by the Member States with EU State aid law. On 30 August 2016, it concluded that Ireland granted undue tax benefits of up to EUR 13 billion to Apple. This White Paper examines and comments on the Commission’s policy on State aid, specifically with regard to the Apple case. View this White Paper


European Union: Blacklists as a tool to fight tax avoidance

Blacklists are a commonly used instrument in the fight against tax avoidance. The European Union recognized the need for a uniform EU framework for addressing tax good governance concerns with third countries and initiated the development of a common EU list of noncooperative jurisdictions. This white paper provides a brief explanation of the EU policy on combating tax avoidance by means of blacklists. View this White Paper


EU Anti-Tax Avoidance Directive – Overview and some prospective effects

On 12 July 2016, the Council of the European Union adopted the Anti-Tax Avoidance Directive (the Directive). The implementation of the rules in the Directive will have several tax consequences at the EU level. This paper provides some brief technical background, describing the adopted rules and their prospective effects. View this White Paper


Tax Treaties: Time for a New Approach?

The author revisits the question of whether tax treaties are necessary, and the possible alternatives to the current bilateral regime. The scholarship of distinguished academics and prominent practitioners, on whether the present treaty architecture adequately meets the demands of the modern-day business and investment landscape, is parsed. View this White Paper


Immovable Property –Harmonization of the Place of Supply

The European Commission has published the Explanatory Notes on the VAT place of supply rules on services connected with immovable property within the legal framework of Implementing Regulation 1042/2013. This white paper analyses the new definition of “immovable property” and when a service is considered to be connected with it. Special focus is given to property management, intermediation and legal services. View this White Paper

Brexit referendum: tax implications of leave vote

On 23 June 2016, UK voters decided to opt out of the European Union. The Brexit will have significant tax consequences. This paper provides some brief technical background, listing the main headings of tax law under which the Brexit will impact the United Kingdom and the European Union. View this White Paper


BEPS-driven implications for M&A transactions

This paper discusses the manner in which expected changes to the tax legislative framework of various jurisdictions, driven by the BEPS proposals, are likely to shape the manner in which M&A transactions are carried out. This is particularity relevant in the current economic context, in which the value of M&A activity has reached unprecedented levels, an ascending trend that is expected to continue in the current year. View this White Paper


Tax Implications of the Amended 2016 Constitution of Zambia

This paper provides a critical review of the taxation provisions in the amended 2016 Constitution of Zambia. It analyses these provisions and lays out the impact that they may have on the prevailing tax laws and on the country's capacity to generate the revenue necessary for national development. Furthermore, the paper discusses the role of Parliament in the implementation of some of these provisions and the capacity building that the legislature may require. View this White Paper


Old Habits Die Hard: Should the United States Abolish Citizenship-Based Taxation?

The dramatic rise in citizenship renunciations by US nationals living overseas is likely pegged to increasingly stringent reporting requirements in particular and to the regime of citizenship-based taxation (CBT) in general. In this paper, the author maintains that the United States should consider scrapping CBT in favour of residence-based taxation (RBT), which is employed by every other OECD member country. View this White Paper


"Options for Low Income Countries’ Effective and Efficient Use of Tax Incentives for Investment": A Response

This White Paper is a summary of the response by IBFD’s Asia-Pacific office to a discussion draft  released by the OECD on options for low income countries' effective and efficient use of tax incentives for investment. View this White Paper


Skandia America – How to deal with supplies between a head office and a fixed establishment in the future

On 17 September 2014, the ECJ gave its decision in the Skandia America case, which generated considerable debate within the VAT community. Member States are compelled to evaluate its effects and to issue guidance accordingly while the European Commission seeks a solution to the issues raised. Until any form of consensus is reached,
Skandia America is likely to lead to confusion and legal uncertainty regarding the treatment of supplies between a head office and fixed establishments that are also part of a VAT group. View this White Paper


Family Unit Taxation in Canada: The Family Tax Cut

This White Paper reviews Canada’s Family Tax Cut, which was recently introduced as an income splitting measure. Against the background of various measures concerning family taxation in Canada and selected countries, the Paper reviews the Family Tax Cut. The Cut does not represent the international norm, and does not seem to achieve its stated objectives. View this White Paper


Have Cost Contribution Arrangements Evolved into Value Contribution Arrangements?

This White Paper provides an overview of the challenges that multinational enterprises (MNEs) will face as a result of the draft guidance on cost contribution arrangements published by the OECD on 29 April 2015. This Paper argues that the focus of the analysis effectively shifts from cost to value contribution. View this White Paper


Can a treaty create taxing rights for a contracting state? – Examining the differences in the definition of “permanent establishment” in Kenya's domestic law and treaties.

This White Paper looks at the definition of permanent establishment (PE) in Kenya's Income Tax Act 1970, as amended (hereinafter “the ITA”), to determine the extent to which the definition is effective in providing certainty as to when a non-resident's activities will be considered to meet the PE threshold and, therefore, taxable in Kenya on business profits from such activities. View this White Paper


US States Challenge Tax Havens

This paper is recommended reading for international tax professionals and academics who are interested in the debate concerning the promulgation of tax haven laws by sub-national jurisdictions. It briefly explains two general principles related to the tax haven laws enacted by US states, namely, the concept of apportionment and the treatment of unitary businesses. The tax haven laws passed in Montana and Oregon contain a list of jurisdictions designated as tax havens. In Washington D.C., West Virginia, Alaska, and Rhode Island, the laws describe statutory criteria to be applied in identifying tax haven jurisdictions. Each state employs a combination of the “worldwide combined unitary reporting” and “water’s edge consolidated return filing” approaches. The paper concludes by reviewing the concerns and criticisms raised with regard to the tax haven laws. View this White Paper


VAT Lotteries – The ultimate road towards tax compliance and social awareness?

This White Paper analyses the use of receipt-based tax lotteries as a technique to increase VAT compliance by incentivizing taxpayers to request receipts, and by fostering a change in taxpayers' attitude towards, specifically, a more tax-compliant society. Experiences with these schemes in EU and non-EU Member States are accordingly reviewed. The successes, and obstacles to success, are highlighted. View this White Paper


Withholding Taxes in the Service of BEPS Action 1: Address the Tax Challenges of the Digital Economy

This position paper provides possible solutions to the challenges presented to the international tax regime by the digital economy. It considers the option of installing a broad withholding mechanism based upon the base erosion principle both as a primary response to these challenges or in support of a new nexus-based solution. View this White Paper


Blueprints for a New PE Nexus to Tax Business Income in the Era of the Digital Economy

In relation to Action 1 of the OECD/G20 BEPS Project, this paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy.

This paper should be understood as a discussion paper to shed further light on (i) whether there is a theoretical justification for a new PE nexus based on digital presence, (ii) how a new PE nexus based on digital presence could be defined and (iii) whether and how potential implementation issues could be resolved. View this White Paper


Restoring integrity of tax systems - a taxing crossroad

BEPS and integrity of tax systems: [...] Some stakeholders appear to have rejected, for example, the long-standing legal notion in tax law that "anyone may arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which best pays the treasury. There is not even a patriotic duty to increase one's taxes".
- Billings Learned Hand. View this White Paper


Tax Policy Trend in Africa - Commentary on the Major Tax Developments of 2013

This paper is a commentary on the major tax policy developments that took place in Africa in 2013. Most of the tax developments discussed are as reported by the Tax News Service of the International Bureau of Fiscal Documentation (IBFD) for the same year. View this White Paper


Cross-border B2C supplies of services requiring cross-border guidelines

This White Paper reviews the challenges facing the OECD in designing VAT/GST guidelines on the place of taxation of cross-border B2C supplies of services. Possible proxies for determining the place of taxation for the various B2C services that could be provided and the methods for collecting and enforcing the VAT/GST, such as supplier registration, will need to be considered. View this White Paper


Emigration and immigration of a business: impact of taxation on European and global mobility - Winning Master Thesis – CFE’s Albert J. Rädler Medal 2013

This research describes the impact of taxation on European and global mobility, focusing on the emigration and immigration of a business from a Dutch tax perspective. Three main criteria are used to assess the current tax system (DTCs, EU law and the benchmark of capital import neutrality), in the light of which the author provides recommendations to improve the current system. In addition, an alternative system is proposed that addresses the problems regarding business migration on an interstate level. View this White Paper


How BEPS May Impact on Existing Group Structures

This White Paper highlights how the OECD's Action Plan on Base Erosion and Profit Shifting (BEPS) impacts existing group structures. The author analyzes the possible effects that BEPS may have on digital trading, intra-group financing, hybrids and dual-resident companies, group finance and licensing companies, foreign permanent establishments and business restructuring/supply change management, and includes a look at some of the related transfer pricing issues. It also observes how some countries have already taken certain of the actions envisaged by BEPS prior to its publication, and some are taking action right now. The IBFD online collection International Tax Structuring covers all of these issues, as well as others in the BEPS Action Plan, as they may impact on an international business at each relevant stage of its development. The collection will continue to track the evolvement of the BEPS plan as it unrolls over the next few years. View this White Paper


Some Thoughts on Convergence and Tax Treaty Interpretation

Article from the Bulletin for International Taxation. View this White Paper


VAT Compliance Record of New Member States

This White Paper reviews the issues regarding the compliance of the new Member States with EU VAT law on the basis of the existing ECJ case law. View this White Paper


The Treatment of Services in Tax Treaties

This White Paper reviews the issues regarding the treatment of services in the UN and OECD Model Tax Conventions, and highlights IBFD’s research on the occurrence of general treaty provisions for entrepreneurial services. The arguments for and against gross and net taxation, and the possibility of a model provision, are explored. View this White Paper


The application of General Anti-Abuse Rules (GAARs) under Double Tax Agreements (DTAs)

This White Paper analyses the approach taken by the OECD regarding the application of domestic anti-abuse measures under Double Tax Agreements and the concerns it raises. View this White Paper


France exempts dividends paid to selected UCITS from dividend withholding tax

This White Paper analyses the conditions pursuant to which French-source dividends paid to a UCITS are exempt from withholding tax, and makes a few practical recommendations. View this White Paper


High tax on high income earners: not the right path to take. 

This White Paper cautions against excessive taxation, and basically adopts the supply-side-economics point of view. View this White Paper


Exchange of Information agreements as a means of combating tax evasion

The liberalization of domestic economies (including the restriction or elimination of the control on foreign investment and of foreign exchange controls) allows persons operating globally to easily shift around not only passive income but also active income. In addition, some jurisdictions also embarked in tax competition including the creation of special offshores regimes to attract the internationally mobile capital. This reality plus the differences in domestic tax systems provide taxpayers the opportunity to benefit from special regimes and also to try to avoid or evade taxation.Confronted with this problem, countries must on the one hand fight for maintaining their tax sovereignty and ensure the correct allocation of taxing rights between tax treaty partners. On the other hand, harmful tax competition has to be addressed by the international community. The aim is to improve transparency and cooperation between tax administrations, the key element being the exchange of information. View this White Paper


Abuso de convenios de doble imposición

Este artículo describe los aspectos generales el problema del abuso de convenios de doble imposición, el cual se ha estudiado en el ámbito internacional, principalmente, en relación con el "mercadeo de tratados"1 (treaty shopping); aunque en ningún caso se limita al mismo. La sección 2 describe el problema del abuso de estos convenios y de su definición (sección 2). La sección 3 describe las medidas que los Estados han adoptado o pueden adoptar para contrarrestar el uso abusivo de estos convenios, considerando asimismo sus limitaciones. Finalmente, la sección 4 analiza, dentro de este contexto, la situación y medidas adoptadas por Chile. View this White Paper


Integrity, ethics for tax administrations

Ethics are the keystones of integrity. But how do we define what is actually right and wrong? The grey area is rather big, in most of the cases; therefore integrity or its lack of it has to be judged from case to case. Some governments actively overlook the lack of integrity as a non-existent issue; some use it as a working tool. View this White Paper


Good Governance and Integrity: presentation given by Prof. Dr Van Kommer during the Commonwealth Business Forum 2009

It is well known that unsatisfactory governance and lack of integrity have a negative influence on a country's economic growth and social welfare. However, despite decades of foreign consultancy, academic research and political advice, the situation has not improved in many parts of the world. The problem is that the fundamentals of good governance and integrity are of western (often Anglo-Saxon) origin but are presented as universal principles, thus denying the importance of domestic values and failing to acknowledge cultural characteristics. Fighting corruption and non-integrity is ineffective if the focus is on foreign standards that cannot be implemented in an environment that is (almost) hostile to non-practical and non-executable advice. Therefore, instances of lack of integrity should first be studied in depth in order to uncover the reasons behind unwanted behaviour, as well as the conditions that facilitate it. In this sense, every case of corruption is an example of the failing conditions of a system that is unable to protect its participants against vulnerable situations. Instead of fighting abuse of the system the aim should be to make organizations and societies healthy and allow new winners to set an example for the next generations. View the presentation


Legitimacy of the State and Taxation

In many articles and books about tax administration and taxation, the concept of “compliance” is introduced and explained. However, the paradigm of the legitimacy of the state is mostly forgotten. It is taken for granted that an essential and common understanding exists between the taxpayer and the state about the obligations of both and about the individual rights of the citizen. View this White Paper


IBFD special monitor - Tax Information Sharing

Since 1938, the International Bureau of Fiscal Documentation (IBFD) has documented the progression of cross-border taxation. One of the more recent progressions has been the developments in transparency and exchange of information regarding tax matters. Much of this activity has been driven by governments’ desire to secure their tax bases during tough economic times as well as the OECD’s advocacy of a threshold to distinguish between jurisdictions which have implemented standards for information sharing and those which have not. View this White Paper


Free Journal Article

New Legislative Tool for Introducing EU-Wide Windfall Taxes

In this free article from our European Taxation Journal, the authors analyse the Commission’s proposal to introduce a new regulation implementing emergency measures with the aim of mitigating high energy prices and the risk of supply shortages in Europe. 

They also examine the legal compatibility of the planned EU windfall tax measures, comparing them to the existing Hungarian windfall taxes. 

Read the free article   

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