Bulletin for International Taxation
| European Union – The Taxation of Permanent Establishments: Selected Issues
Author:HJI Panayi, C. Published online:25 March 2013 2013 (Volume 67), No. 4/5 Bulletin for International Taxation In this article, the author considers recent topical issues arising from the taxation of permanent establishments from the perspective of EU law. |
| Denmark – Transfer Pricing in Denmark
Author:Wittendorff, J. Published online:12 March 2013 2013 (Volume 67), No. 4/5 Bulletin for International Taxation The author, in this article, considers some of the particularities of the Danish transfer pricing regime. Among other things, the article discusses the “marginal market” argument relied on by the Danish tax authorities under which the mere presence of a Danish subsidiary may qualify as a compensable service transaction. |
| International – IFA Turns 75! Proceedings of the IFA 75th Anniversary Jubilee Conference
Author:Michel, B. Published online:12 June 2013 2013 (Volume 67), No. 7 Bulletin for International Taxation On Saturday 2 February 2013, the International Fiscal Association (IFA) celebrated the 75th anniversary of its foundation. A jubilee conference took place in the Peace Palace in The Hague, the Netherlands, exactly where IFA was founded on 12 February 1938. Bob Michel reports on the conference. |
| International/Russia – Transfer Pricing Disputes, Abusive Tax Schemes and the Protection of the European Convention on Human Rights against Oppressive Tax Actions: The Yukos Case
Author:Calderón Carrero, J.M.; Quintas Seara, A. Published online:24 April 2013 2013 (Volume 67), No. 6 Bulletin for International Taxation Following the global financial crisis, taxpayers are subject to more effective levels of taxation and fiscal oversight and tax procedures. The protection of the European Convention on Human Rights against oppressive fiscal actions, arbitrary and pseudo-confiscatory taxation should, however, not be underestimated, as is clearly demonstrated by the Yukos case. |
| International/South Africa – Curbing Thin Capitalization: A Comparative Overview with Reference to South Africa’s Approach – Challenges Posed by the Amended Section 31 of the Income Tax Act 1962
Author:Oguttu, A.W. Published online:23 April 2013 2013 (Volume 67), No. 6 Bulletin for International Taxation The author, in this article, analyses, in an international comparative context, the effectiveness of South Africa’s measures to counter thin capitalization, in light of the 2011 amendments that merged the transfer pricing and thin capitalization rules. This article specifically considers the challenges that the new approach poses to taxpayers. |
| International – The Taxation of Multinational Enterprises: An Elusive Balance
Author:Owens, J.P. Published online:3 July 2013 2013 (Volume 67), No. 8 Bulletin for International Taxation In this article, the author discusses the issue of base erosion and profit shifting, and focuses on its three key aspects: transfer pricing, jurisdiction to tax and anti-avoidance provisions. |
| India/International – TP or Not TP: Examining the Applicability of the Arm’s Length Principle to Inter-Company Equity Financing Transactions
Author:Sanghavi, D.; Schmidt, C.J. Published online:31 July 2013 2013 (Volume 67), No. 9 Bulletin for International Taxation In this article, the authors examine the dynamics of inter-company equity financing transactions and whether or not the arm’s length principle should be applied to them even if they do not |
| India – The Kodak (2013) Case: The Applicability of Indian Transfer Pricing Provisions
Author:Jhabakh, P.R. Kumar Published online:20 August 2013 2013 (Volume 67), No. 10 Bulletin for International Taxation In this article, the author discusses a recent decision of the Income Tax Appellate Tribunal on the applicability of the Indian transfer pricing legislation to domestic transactions, undertaken independently, but as part of a larger global transaction |
| Denmark/Finland/Norway/Sweden – Transfer Pricing in Scandinavian Countries with Reference to the Corporate Income Tax Burden in the 34 OECD Member Countries – Denmark, Finland, Norway and Sweden Compared
Author:Zielke, R. Published online:7 October 2013 2013 (Volume 67), No. 11 Bulletin for International Taxation In the December 2012 issue of the Bulletin for International Taxation, the author compared the holding company regimes in Scandinavian countries and suggested some international tax planning strategies. The author now considers transfer pricing involving Scandinavian countries with reference to the corporate income tax burden in the 34 OECD member countries. |
| International – Starbucks versus the People
Author:Hurk, H.T.P.M. van den Published online:16 December 2013 2014 (Volume 68), No. 1 Bulletin for International Taxation In this article, the author provides his opinion on the current debate on tax avoidance by multinational enterprises. |
| India – India Aims To Reduce Transfer Pricing Disputes through Safe Harbour Rules
Author:Krishnamurthy, V. Published online:16 December 2013 2014 (Volume 68), No. 1 Bulletin for International Taxation In this article, the author describes and evaluates the Indian safe harbour rules, which were introduced with the aim of reducing transfer pricing disputes. |
| International – Base Erosion and Profit Shifting – An Action Plan for Developing Countries
Author:Law, S.B. Published online:27 November 2013 2014 (Volume 68), No. 1 Bulletin for International Taxation In this article, the author discusses the importance of the Base Erosion and Profit Shifting (BEPS) Action Plan for developing countries and the benefits that those countries may realize by participating in the BEPS discussions. |
| United Nations – Tax Treaty News – The United Nations: Recent Tax Developments
Author:Arnold, B.J. Published online:12 November 2013 2013 (Volume 67), No. 12 Bulletin for International Taxation In this Tax Treaty News, Brian Arnold provides his personal opinions and comments on important recent developments regarding the United Nations and tax treaties. |
| International – Interest Deduction Based on the Allocation of Worldwide Debt
Author:Vleggeert, J. Published online:13 January 2014 2014 (Volume 68), No. 2 Bulletin for International Taxation This article proposes to develop a rule that allocates a multinational’s worldwide third-party debt to the group companies using assets as an allocation factor. |
| International – Report of the Proceedings of the Fourth Assembly of the International Association of Tax Judges (30-31 August 2013)
Author:Sachdeva, S. Published online:8 January 2014 2014 (Volume 68), No. 2 Bulletin for International Taxation The report summarizes the proceedings of the Fourth Assembly of the International Association of Tax Judges, held in Amsterdam on 30-31 August 2013. |
| International/Rwanda – Taxing Intra-Company Transfers: The Law and Its Application in Rwanda
Author:Waris, A. Published online:4 November 2013 2013 (Volume 67), No. 12 Bulletin for International Taxation In this article, the author considers the taxation of intra-company transfers and discusses the alternatives to transfer pricing regimes, with special reference to their application to developing countries and, in particular, Rwanda. |
| India – Litigation Strategies, Options and Solutions
Author:Vohra, A. Published online:21 March 2014 2014 (Volume 68), No. 4/5 Bulletin for International Taxation In this article, the author describes the problems faced by the Indian dispute resolution system and provides some recommendations. |
| International/India – Cross-Border Outsourcing – Issues, Strategies and Solutions
Author:Kanabar, D.; Dharawat, R. Published online:21 March 2014 2014 (Volume 68), No. 4/5 Bulletin for International Taxation The economic benefits of cross-border outsourcing are by now well recognized. Despite political and social challenges, both the volume and the range of activities being outsourced have steadily increased. This article discusses tax issues that are seen as a key factor influencing commercial decisions on cross-border outsourcing. |
| India – Recent Important Indian Tax Cases
Author:Sheth, N.; Thakkar, N. Published online:19 March 2014 2014 (Volume 68), No. 4/5 Bulletin for International Taxation In this article, the authors discuss some of the recent Indian rulings laying down important principles in tax matters. |
| OECD – Intangibles and Location Benefits (Customer Base)
Author:Wilkie, J.S. Published online:13 May 2014 2014 (Volume 68), No. 6/7 Bulletin for International Taxation In this article, the author analyses the issue of intangibles and location benefits, including the customer base, in relation to the OECD Base Erosion and Profit Shifting initiative. |
| OECD – International Taxation of Risk
Author:Schön, W. Published online:21 May 2014 2014 (Volume 68), No. 6/7 Bulletin for International Taxation The contractual allocation of risk belongs to the central topics of international tax policy. This article points out that risk shifting is essentially tax-neutral, but there are three areas of concern which have to be discussed: asymmetrical risk allocation, taxation of risk premiums and the tax treatment of “hidden intangibles”. |
| OECD – Base Erosion and Profit Shifting and Interest Expenditure
Author:Hey, J. Published online:21 May 2014 2014 (Volume 68), No. 6/7 Bulletin for International Taxation In this article, the author examines the implications for the utilization of interest expenditure in tax planning given the OECD Base Erosion and Profit Shifting initiative. |
| International – Toll and Contract Manufacturing Structures – Strategies and Challenges for Cross-Border Outsourcing Activities
Author:Rodríguez Cuadros, M.A. Published online:15 October 2014 2014 (Volume 68), No. 11 Bulletin for International Taxation In this article, the author explains toll and contract manufacturing structures and their tax, trade and customs implications for principals, tollers and contractors. |
| International – Cross-Border Outsourcing – Issues, Strategies and Solutions
Author:Mies, H. Published online:24 September 2014 2014 (Volume 68), No. 10 Bulletin for International Taxation This article, which was drafted on the occasion of the 68th Congress of the International Fiscal Association in Mumbai, India, addresses tax-related issues, strategies and solutions regarding cross-border outsourcing. |
| OECD/International – The Effect of the OECD Base Erosion and Profit Shifting Action Plan on Developing Countries
Author:Wagenaar, L. Published online:12 January 2015 2015 (Volume 69), No. 2 Bulletin for International Taxation In this article, the author describes some of the typical features of tax systems of developing countries and discusses how the OECD Base Erosion and Profit Shifting Initiative affects such countries and their tax systems. |
| International – Procedural Instruments as a Way To Deal with Valuation Uncertainty in International Tax Law
Author:Seer, R. Published online:29 January 2014 2014 (Volume 68), No. 3 Bulletin for International Taxation In this article, the author looks at the problem of valuation uncertainty and examines procedural instruments that can be used to mitigate it. |
| OECD – Transparency in Financial Reporting: Is Country-by-Country Reporting Suitable To Combat International Profit Shifting?
Author:Evers, M.T.; Meier, I.; Spengel, C. Published online:15 April 2014 2014 (Volume 68), No. 6/7 Bulletin for International Taxation In this article, the authors contend that country-by-country reporting cannot be regarded as a convincing measure to combat international profit shifting. Instead, tax legislators should limit profit shifting by enforcing national and international tax rules and by closing gaps in tax law. |
| Switzerland/OECD – Switzerland in a Post-BEPS World
Author:Danon, R.J.; Schelling, C. Published online:30 March 2015 2015 (Volume 69), No. 4/5 Bulletin for International Taxation The authors, in this contribution, consider the implications of the OECD Base Erosion and Profit Shifting project, on Swiss corporate tax policy. While they generally support the BEPS project, the authors believe that its implementation should also take national tax policies differences into account. |
| United Nations – Report on the Tenth Session of the United Nations Committee of Experts on International Cooperation in Tax Matters
Author:Arnold, B.J. Published online:16 February 2015 2015 (Volume 69), No. 3 Bulletin for International Taxation This article reports on the Tenth Session of the United Nations Committee of Experts on International Cooperation in Tax Matters regarding the various issues considered in relation to the next update of the UN Model and the Commentaries on the UN Model, which are planned to be published in 2017. |
| South Africa – Hybrid Debt and Hybrid Equity Instruments and the Interest Limitation Rules in South Africa
Author:Mazansky, E. Published online:30 January 2015 2015 (Volume 69), No. 3 Bulletin for International Taxation In this article, the author examines the South African tax rules relating to hybrid debt and hybrid equity instruments, particularly with a view either to disallowing deductions or taxing receipts. Some observations are also made on the related interest limitation rules, which prevent excessive interest deductions |
| OECD/International – Public Discussion Draft on Interest Deductions Proposes Worldwide Interest Allocation Rules
Author:Vleggeert, J. Published online:30 March 2015 2015 (Volume 69), No. 4/5 Bulletin for International Taxation This article examines the approach to tackle BEPS through the use of interest cost, which was presented in the OECD public discussion draft on interest deductions and other financial payments. |
| OECD – Labour Rents, Arm’s Length Transfer Pricing and Intangibles: Still Searching for a Solution to the BEPS
Author:Kane, M.A. Published online:8 May 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation In this article, the author critically evaluates the tax treatment of “location savings” proposed by the OECD Base Erosion and Profit Shifting (BEPS) project. |
| Africa – Tax Policy Trends in Africa – Commentary on the Major Tax Developments in 2013 and 2014
Author:Munyandi, K.; Hamzaoui, R.; Gutiérrez Puente, C.; Ogazón Juárez, L.G.; Marinho, A. Trindade; Montes Ventura, M.; Naoum, M.; Muyaa, E. Published online:24 February 2015 2015 (Volume 69), No. 3 Bulletin for International Taxation The authors, in this article, comment on the most significant tax policy trends and developments that occurred in Africa in 2013 and 2014, together with providing an analysis, both theoretically and globally, of the relevant tax changes. The article also considers potential future tax policy developments in Africa. |
| International – Is the Mutual Agreement Procedure Past Its “Best-Before Date” and Does the Future of Tax Dispute Resolution Lie in Mediation and Arbitration?
Author:Sidhu, P.K. Published online:22 October 2014 2014 (Volume 68), No. 11 Bulletin for International Taxation This article examines dispute resolution mechanisms under tax treaties and bilateral investment agreements, with a particular focus on mutual agreement procedure (MAP). It concludes that the MAP is not efficient at dispute resolution and more attention should be paid to alternative methods of dispute resolution, such as arbitration and mediation. |
| Australia/OECD – The Interface between the New Australian Transfer Pricing Regime and the OECD BEPS Report and Action Plan
Author:Gonzaga, L. Published online:16 July 2014 2014 (Volume 68), No. 8 Bulletin for International Taxation This article critically examines the recent changes to the Australian transfer pricing legislation in light of the OECD reports on base erosion and profit shifting (BEPS). |
| India/International – Tax Aspects of Cross-Border Secondment of Employees to India
Author:Krishnamurthy, V. Published online:16 January 2015 2015 (Volume 69), No. 2 Bulletin for International Taxation In this article, the author examines the tax aspects of cross-border secondments of employees to India, with special reference to the significant tax implications for the foreign entities and Indian entities involved, as well as for the employees themselves. |
| International – Country-by-Country Reporting: A New Approach towards Book-Tax Conformity
Author:Stasio, A. Published online:22 January 2015 2015 (Volume 69), No. 2 Bulletin for International Taxation In this article, the author argues that increased book-tax conformity can be achieved through improved documentation, in particular in the field of transfer pricing, and through country-by-country reporting. |
| United Nations – The UN Model in Practice 1997–2013
Author:Wijnen, W.F.G.; Goede, J.J.P. de Published online:17 February 2014 2014 (Volume 68), No. 3 Bulletin for International Taxation This research was carried out at the request of the Committee of Experts on International Co-operation in Tax Matters of the United Nations and focuses on the use of the specific UN Model provisions in tax treaties concluded in the 1997 to 2013 period. |
| European Union/OECD – Country-by-Country Reporting: The Primary Concerns Raised by a Dynamic Approach
Author:Grau Ruiz, M.A. Published online:18 September 2014 2014 (Volume 68), No. 10 Bulletin for International Taxation The author examines potential implications of country-by-country reporting in relation to the OECD Base Erosion and Profit Shifting initiative and compares it with the previous Corporate Social Responsibility approach within the European Union. |
| Switzerland/OECD – Potential Effects of the OECD Base Erosion and Profit Shifting Initiative on Swiss Transfer Pricing Rules and Swiss Companies
Author:Stocker, R. Published online:27 March 2015 2015 (Volume 69), No. 4/5 Bulletin for International Taxation In this contribution, the author considers the implications of the Base Erosion and Profit Shifting initiative of the OECD with regard to Switzerland’s transfer pricing practice, Swiss companies and potential changes to Swiss tax law. |
| Switzerland – Practical Protection of the Fundamental Rights of Taxpayers
Author:Desax, R. Published online:20 March 2015 2015 (Volume 69), No. 4/5 Bulletin for International Taxation In this article, the author examines selected practical aspects of the protection of the fundamental rights of taxpayers in Switzerland, together with the enforcement of these rights as well as obstacles that frequently arise in practice. |
| OECD/International – Interest Deductions and Multinational Enterprises: Goldilocks and the Brave New World
Author:Burnett, C. Published online:28 May 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation This article compares the “brave new” group-wide approach under Action 4 of the G20/OECD Base Erosion and Profit Shifting initiative to the fixed ratio alternative. The conclusion is that the group-wide approach, which is not as novel as some assume, should be supported. Resisting the “Goldilocks” standard of perfection, it can be combined with a modest fixed ratio safe harbour. |
| India/OECD – Base Erosion and Profit Shifting: An Indian Perspective
Author:Sengupta, D.P.; Rao, R.K. Published online:22 May 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation In this article, the authors review the economic and legal evidence of base erosion and profit shifting (BEPS) in India. |
| OECD/United States – The Politics of BEPS – Apple’s International Tax Structure and the US Attitude towards BEPS
Author:Ting, A. Published online:12 May 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation This article aims to highlight the US attitude towards BEPS (as revealed by the hearings regarding the international tax structures of Apple and Caterpillar) and suggests that the attitude does not seem to have changed in the BEPS Project so far. |
| OECD/Canada – Action 4 of the OECD Action Plan on Base Erosion and Profit Shifting Initiative: Interest and Base-Eroding Payments – Insights from the Canadian Experience
Author:Duff, D.G. Published online:11 May 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation This article provides a Canadian perspective of Action 4 of the OECD Action Plan on Base Erosion and Profit Shifting. The Canadian experience suggests that countries acting on a unilateral basis are more concerned by base erosion undertaken by non-residents than by residents. |
| International – Location-Specific Advantages: When and How They Should Be Allocated
Author:Bilaney, S.K. Published online:26 June 2015 2015 (Volume 69), No. 8 Bulletin for International Taxation In this article, the author explains the concept of location-specific advantages, analyses when and how they should be allocated between multinational enterprise (MNE) groups based on the guidance provided in the United Nations Practical Manual on Transfer Pricing for Developing Countries (the UN Manual), Action 8 of the Action Plan on Base Erosion and Profit Shifting (Action 8), and in light of recent case law. Further, the approach adopted by the Indian and Chinese authorities is discussed. |
| OECD/International/China (People’s Rep.) – China and BEPS: From Norm-Taker to Norm-Shaker
Author:Li, J. Published online:12 June 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation In this article, the author considers the implications for China of the G20/OECD Base Erosion and Profit Shifting (BEPS) initiative and the international implications of China’s BEPS measures. |
| International/OECD – Developing Countries’ Reactions to the G20/OECD Action Plan on Base Erosion and Profit Shifting
Author:Peters, C. Published online:11 June 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation This article describes and examines the reactions of developing countries to the G20/OECD Action Plan on Base Erosion and Profit Shifting as communicated to the Subcommittee on Base Erosion and Profit Shifting Issues for Developing Countries of the UN Committee of Experts on International Cooperation in Tax Matters. |
| International/OECD – Emissions Trading and Tax Treaties
Author:Ismer, R.; Haussner, M. Published online:14 July 2015 2015 (Volume 69), No. 8 Bulletin for International Taxation Various countries have either contemplated introducing or implemented emissions trading schemes to mitigate climate change. Such schemes raise questions not only in relation to accounting and domestic taxation, but also regarding tax treaties that can be satisfactorily resolved by clarifications in the Commentaries on the OECD Model and UN Model. |
| Brazil – The Brazilian Tax Implications of Cross-Border Remittances Arising from International Cost-Sharing Arrangements
Author:Castro, L. Freitas de Moraes e Published online:13 July 2015 2015 (Volume 69), No. 8 Bulletin for International Taxation In this article, the author considers the international tax implications for the parties involved of international cost-sharing arrangements and, in particular, the arguments supporting the non-imposition of various Brazilian taxes with regard to payments made in relation to such agreements. |
| Australia – The Australian Offshore Banking Unit Regime: Modernizing the Rules
Author:Joseph, A. Published online:9 September 2015 2015 (Volume 69), No. 10 Bulletin for International Taxation The author, in this article, explains the operation of the Offshore Banking Unit (OBU) regime in Australia before and after the recent amendments to it. The changes apply as from the beginning of July 2015. |
| International/OECD – Human Capital in Value Creation and Post-BEPS Tax Policy: An Outlook
Author:Tavares, R.J.S.; Owens, J.P. Published online:7 September 2015 2015 (Volume 69), No. 10 Bulletin for International Taxation In this article, the authors propose the debate of “evolutionary” international tax reform, inter alia, revisiting the current discussion on base erosion and profit shifting (BEPS), and suggesting a renewed emphasis on knowledge-based capital within the framework of the arm’s length principle in respect of transfer pricing and other specific anti-avoidance rules. |
| International/OECD – Abuse and Economic Substance in a Digital BEPS World
Author:Stewart, M. Published online:11 June 2015 2015 (Volume 69), No. 6/7 Bulletin for International Taxation In this article, the author considers the key issues of abuse and economic substance in relation to the G20/OECD Base Erosion and Profit Shifting initiative, with special emphasis on Action 1 and Action 6 of the OECD Action Plan. |
| Japan/OECD – Introduction of the Authorised OECD Approach into Japanese Domestic Law
Author:Masui, Y. Published online:13 August 2015 2015 (Volume 69), No. 9 Bulletin for International Taxation In this article, the author discusses the background, core elements and implications of the 2014 tax reform in Japan, which introduced the Authorised OECD Approach (AOA) into Japan’s domestic law. |
| India – Transfer Pricing Aspects of Marketing Intangibles: An Indian Perspective
Author:Wagh, S. Published online:24 July 2015 2015 (Volume 69), No. 9 Bulletin for International Taxation In this article, the author considers the transfer pricing aspects of marketing intangibles from an Indian viewpoint, with particular emphasis on the controversy surrounding this subject. The author also analyses recent developments on the transfer pricing of marketing intangibles with regard to the OECD’s Base Erosion and Profit Shifting (BEPS) project. |
| International/European Union/OECD – Centralized Intellectual Property Business Models – Tax Implications of EU Patent Box Regimes
Author:Zammit, I. Published online:6 August 2015 2015 (Volume 69), No. 9 Bulletin for International Taxation This article provides a broad overview of the developments at the global and EU level regarding the tax effects of the adoption of centralized intellectual property business models. In this respect, the author specifically addresses patent box regimes and measures to counter aggressive tax planning and harmful tax competition. |
| European Union/Netherlands/OECD – The Netherlands Court of Audit: An Audit on Tax Avoidance
Author:Koot, H.; Rijke, M. de Published online:12 October 2015 2015 (Volume 69), No. 11 Bulletin for International Taxation In this article, the authors describe, from an international perspective, the procedures performed by the Netherlands Court of Audit with regard to tax collection, and address recent initiatives of the international community to counter tax avoidance by multinational enterprises. |
| International/OECD – OECD’s Action Plan on Tax Base Erosion and Profit Shifting: Part 1 – What Should Be Africa’s Response?
Author:Oguttu, A.W. Published online:7 October 2015 2015 (Volume 69), No. 11 Bulletin for International Taxation In Part 1 of this article, the author first explains the thinking and concepts behind the OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) and then addresses the relevance of the OECD BEPS Action Plan to Africa and what should be the African response to the Plan. |
| Brazil – The Tax and Regulatory Limitations on International Remittances of Royalties from Brazil
Author:Castro, L. Freitas de Moraes e Published online:9 November 2015 2015 (Volume 69), No. 12 Bulletin for International Taxation In this article, the author considers the tax and regulatory restrictions regarding the international remittance of payments in respect of royalties and fees for technical assistance in Brazil and provides recommendations for taxpayers to mitigate the adverse effects of these rules. |
| International/OECD – Seeking New Directions in Dispute Resolution Mechanisms: Do We Need a Revised Mutual Agreement Procedure?
Author:Markham, M. Published online:13 January 2016 2016 (Volume 70), No. 1/2 Bulletin for International Taxation This article examines issues in reforming the mutual agreement procedure (MAP), drawing on concerns raised by various organizations, especially the OECD. It evaluates perceived obstacles to the functioning of this aspect of the global tax environment and considers new directions in reforming the MAP process that could enhance controversy management. |
| International/OECD – The Compatibility of the OECD/G20 Base Erosion and Profit Shifting Proposals with EU Law
Author:HJI Panayi, C. Published online:27 November 2015 2016 (Volume 70), No. 1/2 Bulletin for International Taxation This article examines the compatibility of the proposals produced in respect of the OECD/G20 Base Erosion and Profiting Shifting Action Plan with EU law. Where relevant, the author also reviews the compatibility of the recent EU measures that address aggressive tax planning. |
| International/OECD – Comments on Professor Schoueri’s Lecture “Arm’s Length: Beyond the Guidelines of the OECD”
Author:Andresen, U. Published online:24 November 2015 2015 (Volume 69), No. 12 Bulletin for International Taxation Dr Ulf Andresen comments on Professor Schoueri’s Klaus Vogel Lecture of 25 September 2015, hosted by the Institute for Austrian and International Tax Law (WU), Vienna, the title of which was “Arm’s Length: Beyond the Guidelines of the OECD”. |
| International/OECD – Arm’s Length: Beyond the Guidelines of the OECD
Author:Schoueri, L.E. Published online:23 November 2015 2015 (Volume 69), No. 12 Bulletin for International Taxation In the Klaus Vogel Lecture of 25 September 2015, hosted by the Institute for Austrian and International Tax Law (WU), Vienna, Prof. Luís Eduardo Schoueri undertook an in-depth consideration of the arm’s length standard (ALS) in relation to transfer pricing issues and the current status of the ALS. |
| International/OECD – A Change of Paradigm in International Tax Law: Article 7 of Tax Treaties and the Need To Resolve the Source versus Residence Dichotomy
Author:Bianco, J.F.; Tomazela Santos, R. Published online:24 February 2016 2016 (Volume 70), No. 3 Bulletin for International Taxation The authors, in this article, consider the problem of, and the potential solution to, the need to resolve the dichotomy between source and residence taxation with regard to international taxation and tax treaties. |
| Australia/OECD – The OECD Base Erosion and Profit Shifting Initiative in an Australian Context – The Current State of Play
Author:Joseph, A. Published online:17 February 2016 2016 (Volume 70), No. 3 Bulletin for International Taxation This article describes the significant steps that the Australian government has taken within the context of the OECD Base Erosion and Profit Shifting initiative regarding transfer pricing reporting requirements, the digital economy and goods and services tax, permanent establishment status, and controlled foreign company and thin capitalization legislation. |
| Saudi Arabia – Taxation of Foreign Multinational Enterprises Conducting Business in and with Saudi Arabia
Author:Gidirim, V.A. Published online:14 March 2016 2016 (Volume 70), No. 4 Bulletin for International Taxation In this article, the author considers the tax implications of Saudi Arabian domestic law (outbound payments, permanent establishment issues) and the tax treaties that Saudi Arabia has concluded for multinational enterprises doing business in and with Saudi Arabia. The article also provides insights into the practices of local tax authorities. |
| International/OECD – The BEPS Package: Promise Kept
Author:Saint-Amans, P.; Russo, R. (Raffaele) Published online:16 March 2016 2016 (Volume 70), No. 4 Bulletin for International Taxation This article considers the work already undertaken by the G20 and OECD member countries in developing the BEPS Action Plan, discusses the implementation of this ambitious initiative and concludes that the final outcome represents a restoration of integrity and coherence to the international tax system. |
| China (People’s Rep.) – Advance Pricing Agreements in China
Author:Na, L. Published online:11 April 2016 2016 (Volume 70), No. 5 Bulletin for International Taxation The author, in this article, describes the legal framework and current status of concluding advance pricing agreements (APAs) in China and considers possible development with regard to Chinese APAs. |
| Brazil – Transfer Pricing in Brazil and Actions 8, 9, 10 and 13 of the OECD Base Erosion and Profit Shifting Initiative
Author:Valadão, M.A. Pereira Published online:25 April 2016 2016 (Volume 70), No. 5 Bulletin for International Taxation Actions 8, 9, 10 and 13 of the OECD Base Erosion and Profit Shifting (BEPS) initiative directly relate to transfer pricing. This article discusses how the transfer pricing related outcomes of the BEPS Project could affect the Brazilian transfer pricing legislation and the particular Brazilian approach to this issue. |
| Africa/International/OECD – OECD’s Action Plan on Tax Base Erosion and Profit Shifting: Part 2 – A Critique of Some Priority OECD Actions from an African Perspective – Addressing Excessive Interest Deductions, Treaty Abuse and the Avoidance of the Status of a Permanent Establishment
Author:Oguttu, A.W. Published online:23 May 2016 2016 (Volume 70), No. 6 Bulletin for International Taxation The author, in Part 2 of this article, continues her examination of the implications of the OECD’s Action Plan on Base Erosion and Profit Shifting from an African perspective, with particular emphasis on excessive interest deductions, treaty abuse and the avoidance of the status of a permanent establishment. |
| International/OECD – Mind the Gap: The Role of Politics and the Impact of Cultural Differences on the OECD BEPS Project
Author:Myszkowski, A. Published online:25 April 2016 2016 (Volume 70), No. 5 Bulletin for International Taxation In this article, the author considers the achievements of the OECD Base Erosion and Profit Shifting Project using socio-economic-political approaches, and attaching special attention to the failure to address problems related to the impact of cultural differences on the interpretation of anti-abuse provisions. |
| International/OECD – Understanding Risk in the Era of the OECD/G20 Base Erosion and Profit Shifting Initiative
Author:Bilaney, S.K. Published online:5 September 2016 2016 (Volume 70), No. 10 Bulletin for International Taxation The concept of “risk” is not new to transfer pricing, but different stakeholders have different perceptions, which may result in divergent views. The OECD/G20 in their Base Erosion and Profit Shifting initiative have created a framework to analyse risk in controlled transactions. This article examines this framework using practical examples. |
| International/OECD – Can Cooperative Compliance Help Developing Countries Address the Challenges of the OECD/G20 Base Erosion and Profit Shifting Initiative?
Author:Pemberton, J.L.; Majdańska, A. Published online:2 September 2016 2016 (Volume 70), No. 10 Bulletin for International Taxation Developing countries arguably have the most at stake in the efforts to counter base erosion and profit shifting, but face the biggest challenges. In this context, the authors address the question of whether cooperative compliance between tax administrations and taxpayers has a role to play in these efforts.
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| Spain – The Spanish Transfer Pricing Regime and the OECD/G20 Base Erosion and Profit Shifting Project
Author:Calderón Carrero, J.M. Published online:18 July 2016 2016 (Volume 70), No. 8 Bulletin for International Taxation This article provides an overview of the Spanish transfer pricing regime with an especial focus on the effects and implications for this regime of the OECD/G20 Base Erosion and Profit Shifting Project. |
| Spain – The Spanish General Anti-Abuse Rule
Author:Palao Taboada, C. Published online:18 July 2016 2016 (Volume 70), No. 8 Bulletin for International Taxation The author, in this article, considers the evolution, together with the implications, of the Spanish general anti-abuse rule since it first introduction in 1963, with especial reference to the current version of 2004, as amended in 2015. |
| Angola/Cape Verde/Mozambique/São Tomé and Príncipe – Portuguese-Speaking African Countries: Same Background, Different Solutions
Author:Graça, T. Machado Published online:8 November 2016 2016 (Volume 70), No. 12 Bulletin for International Taxation This article presents an overview of the international taxation aspects of the domestic tax legislations of Angola, Mozambique, Cape Verde, and São Tomé and Príncipe with regard to the direct taxation of companies |
| International/OECD – International Taxation and Economic Substance
Author:Picciotto, S. Published online:1 November 2016 2016 (Volume 70), No. 12 Bulletin for International Taxation This article argues that the “independent entity principle” is a basic flaw in the current system for taxing multinational enterprises (MNEs), creating problems especially for developing countries, which the OECD/G20 Base Erosion and Profit Shifting initiative has failed to resolve; it describes three alternative approaches that could be adopted to move towards a unitary approach to MNE taxation, and considers the prospects for the current transitional period. |
| Ghana – Ghana’s Transfer Pricing Regime: The Current Situation and Suggestions for Improvement
Author:Ali-Nakyea, A.; Owusu Demitia, W.K. Published online:28 October 2016 2016 (Volume 70), No. 12 Bulletin for International Taxation In this article, the authors examine the issues that are emerging following the recent introduction of Ghana’s transfer pricing regime, and propose the adoption of safe harbours to deal with the immediate and serious problems that could otherwise arise following the implementation of the regime. |
| European Union/International/OECD – International Tax Law Following the OECD/G20 Base Erosion and Profit Shifting Project
Author:HJI Panayi, C. Published online:14 October 2016 2016 (Volume 70), No. 11 Bulletin for International Taxation This article considers the implications of the OECD/G20 Base Erosion and Profit Shifting initiative on international tax law. It specifically questions whether the final deliverables address the problems identified at the inception of the initiative and examines the potential effects on the development of international and EU tax law. |
| Brazil/Netherlands – Dutch Holding Companies Included in Brazilian Grey List: Controlled Foreign Company, Thin Capitalization and Consolidation Rules Not Applicable for 2015
Author:Castro, L. Freitas de Moraes e Published online:13 October 2016 2016 (Volume 70), No. 11 Bulletin for International Taxation This article considers the material and temporal extent and effect of the changes to the Brazilian list of privileged tax regimes in relation to Dutch holding companies and, specifically, if these changes have implications for 2015 that affect filing in respect of the Escrituração Contábil Fiscal (Digital Accounting Register, ECF) in 2016.
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| Switzerland/European Union/OECD – The Swiss Tax Ruling Practice: Recent Domestic and International Developments
Author:Kläser, J. Published online:28 December 2016 2017 (Volume 71), No. 1 Bulletin for International Taxation In today’s tax world, tax rulings are often considered obstacles to transparency and the fight against tax avoidance. Ever since LuxLeaks, the low level of transparency in corporate taxation has been recognized in the public debate. In this article, the author examines the Swiss ruling practice from both a domestic and an international perspective, with a special focus on the effects of the OECD/G20 Base Erosion and Profit Shifting initiative on the ruling practice. |
| Hong Kong/Singapore/International/OECD – The Territoriality Principle in the World of the OECD/G20 Base Erosion and Profit Shifting Initiative: The Cases of Hong Kong and Singapore – Part II
Author:See, W.H. Published online:21 December 2016 2017 (Volume 71), No. 2 Bulletin for International Taxation In Part II of this article, the author examines the effect of the territoriality principle on tax treaties concluded by Singapore and Hong Kong. This is followed by an analysis of the interaction between the territoriality principle and the OECD/G20 Base Erosion and Profit Shifting initiative. |
| United States/International – O Brave New World: The Looming Rethink of International Taxation in the United States
Author:Rosenbloom, H.D. Published online:19 December 2016 2017 (Volume 71), No. 2 Bulletin for International Taxation In the Klaus Vogel Lecture of 23 September 2016, hosted by the Institute for Austrian and International Tax Law (WU), Vienna, David Rosenbloom provides his thoughts and observations on the, in his view necessary, reform of the international taxation system of the United States. |
| Brazil/International/OECD – Action 14 of the OECD/G20 Base Erosion and Profit Shifting Initiative: Making Dispute Resolution More Effective – Did Action 14 “Piggyback” on the Initiative?
Author:Oliveira, P. Toledo Pires de Published online:13 December 2016 2017 (Volume 71), No. 1 Bulletin for International Taxation This article examines Action 14 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative with regard to making dispute resolution more effective in respect of mutual agreement procedures and whether Action 14 is an integral part of the BEPS Action Plan or has simply been tacked onto the initiative. |
| India/OECD – Indian Transfer Pricing Round-Up for 2016
Author:Bilaney, S.K. Published online:2 December 2016 2017 (Volume 71), No. 1 Bulletin for International Taxation In this article, the author analyses the significant developments in Indian transfer pricing rules in 2016, including amendments to existing regulations to align these with the OECD/G20 Base Erosion and Profit Shifting initiative, relevant court decisions, the success of the Indian advance pricing agreement programme, and changes regarding related-party transactions |
| Spain – The Spanish Position on the Concept of a Permanent Establishment: Anticipating BEPS, beyond BEPS or Simply a Wrong Interpretation of Article 5 of the OECD Model?
Author:Martín Jiménez, A.J. Published online:13 July 2016 2016 (Volume 70), No. 8 Bulletin for International Taxation In this article, the author considers the Spanish position regarding the concept of a permanent establishment and whether the Spanish concept conforms to the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative or is simply an erroneous interpretation of the provisions of article 5 of the OECD Model. |
| Spain – Encouraging Research and Development (and Innovation) in the Spanish Tax System
Author:Soler Roch, M.T.; Gil García, E. Published online:13 July 2016 2016 (Volume 70), No. 8 Bulletin for International Taxation This article examines the tax system for research and development (and innovation) (R&D (&I)) in Spain. Generally, the Spanish tax system encourages R&D (&I) by granting a wide range of incentives with regard to R&D (&I), as companies may benefit from input and output incentives in respect of such activities. |
| Tanzania – Mining Taxation in Tanzania: The African Barrick Gold Cases
Author:Waris, A. Published online:11 November 2016 2016 (Volume 70), No. 12 Bulletin for International Taxation This article considers the changes made to Tanzanian mining law in relation to the issues that were highlighted in three recent cases involving the mining subsidiaries of African Barrick Gold, which concerned various tax issues. It then discusses how the cases elaborated on the tax law in question |
| China (People’s Rep.) – Status of the Implementation of the OECD/G20 BEPS Initiative in China and Future Developments
Author:Na, L. Published online:20 January 2017 2017 (Volume 71), No. 2 Bulletin for International Taxation The author, in this article, describes the status of the OECD/G20 Base Erosion and Profit Shifting initiative in China as at the end of 2016 and attempts to predict the further actions that China may take to continue the implementation of the initiative in the future. |
| Argentina/Panama/OECD/WTO – World Trade Organization Finding on Anti-Avoidance Measures To Counter Foreign Preferential Tax Regimes versus the Free Flow of Capital and Investment
Author:Ramírez, G. Published online:20 January 2017 2017 (Volume 71), No. 2 Bulletin for International Taxation This article considers the tax implications of the dispute brought before the World Trade Organization by Panama in relation to measures implemented by Argentina in response to the OECD/G20 Base Erosion and Profit Shifting initiative. |
| United States/International – Comments on Professor David Rosenbloom’s Lecture “O Brave New World: The Looming Rethink of International Taxation in the United States”
Author:Kraft, G. Published online:12 January 2017 2017 (Volume 71), No. 2 Bulletin for International Taxation Prof. Dr Gerhard Kraft comments on Professor Rosenbloom’s Klaus Vogel Lecture of 23 September 2016, hosted by the Institute for Austrian and International Tax Law (WU), Vienna, the title of which was “O Brave New World: The Looming Rethink of International Taxation in the United States”. |
| China (People’s Rep.)/International/OECD – Location-Specific Advantages: A Rising Disruptive Factor in Transfer Pricing
Author:Li, J.; Ji, S. Published online:22 March 2017 2017 (Volume 71), No. 5 Bulletin for International Taxation In this article, the authors consider location-specific advantages (LSAs) in transfer pricing analysis, with a special emphasis on the practice in China. They suggest that LSAs disrupt some of the basic assumptions underlying the current consensus on the application of the arm’s length principle without, arguably, violating the purpose of the principle as stated in article 9 of the OECD Model. |
| Ireland/United Kingdom/OECD – The Relationship between Tax Authorities, Large Multinationals and the Public
Author:Daly, S. Published online:20 March 2017 2017 (Volume 71), No. 5 Bulletin for International Taxation In this article, the author explores accusations levelled at the revenue authorities of Ireland and the United Kingdom in response to their treatment of multinationals, analyses the statutory scheme underpinning the powers of those revenue authorities and provides a preliminary proposition as to why subsequent developments have been so distinct. |
| International/OECD/United Nations – The UN Committee of Experts and the UN Model: Recent Developments
Author:Arnold, B.J. Published online:22 February 2017 2017 (Volume 71), No. 3/4 Bulletin for International Taxation This article reports on the Twelfth and Thirteenth Sessions of the UN Committee of Experts on International Cooperation in Tax Matters regarding the various issues considered in relation to the next update of the UN Model and the Commentaries on the UN Model, which are planned to be published later this year. |
| Brazil – Brazilian Anti-Avoidance Legislation: Recent Refinements and Major Deviations from International Practice
Author:Bianco, J.F.; Tomazela Santos, R. Published online:26 April 2017 2017 (Volume 71), No. 6 Bulletin for International Taxation The authors, in this article, consider the main features of the Brazilian anti-avoidance legislation, thereby providing a general overview of the topic |
| International/European Union/OECD – An Evaluation of the Measures in Action 14 of the Action Plan of the OECD/G20 BEPS Initiative Intended to Make Dispute Resolution More Effective
Author:Arora, H. Published online:21 April 2017 2017 (Volume 71), No. 5 Bulletin for International Taxation Action 14 of the Action Plan, which is part of the OECD/G20 Base Erosion and Profit Shifting initiative, is intended to strengthen the mutual agreement procedure. This article discusses how these measures propose to minimize the risks of uncertainty and unintended double taxation. |
| International/OECD – Revised OECD Draft Guidance on the Profit Split Method: The Need for Conceptual Refinements!
Author:Bilaney, S.K. Published online:4 April 2017 2017 (Volume 71), No. 5 Bulletin for International Taxation This article provides a critical overview of the OECD’s revised draft guidance on the transfer pricing profit split method and makes important suggestions as to how to make the method more practical in its application. |
| International/OECD – Is the OECD/G20 BEPS Initiative Heading in the Right Direction? Some Forgotten (and Uncomfortable) Questions
Author:Escribano, E. Published online:4 April 2017 2017 (Volume 71), No. 5 Bulletin for International Taxation This article critically analyses the scope of the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative and further raises some questions concerning the role played by certain long-standing paradigms underlying corporate income taxation in the BEPS phenomenon. |
| European Union/OECD – The Changing Contours of Dispute Resolution in the International Tax World: Comparing the OECD Multilateral Instrument and the Proposed EU Arbitration Directive
Author:Govind, S.P.; Turcan, L. Published online:22 February 2017 2017 (Volume 71), No. 3/4 Bulletin for International Taxation This article considers the most significant changes proposed in the Multilateral Instrument and the EU Arbitration Directive and compares their scope and effectiveness along with their interaction so as to point out issues and to propose recommendations for more uniformly acceptable solutions. |
| International/OECD/United Nations – How “Limited” Is Limited Force of Attraction? An Analysis of the Relevant Case Law and the Potential Implications of the OECD/G20 BEPS Initiative
Author:Sagar, S. Published online:13 February 2017 2017 (Volume 71), No. 3/4 Bulletin for International Taxation This article considers the scope of the limited force of attraction principle as set out in article 7 of the UN Model, focusing on its development, the relevant case law and the potential implications for the principle in the light of the OECD/G20 Base Erosion and Profit Shifting initiative. |
| China (People’s Rep.) – Is China Internationally Tax Competitive?
Author:Chen, C-H. Published online:11 January 2017 2017 (Volume 71), No. 2 Bulletin for International Taxation Foreign-invested enterprises (FIEs) minimize their tax burden through transfer pricing or the use of lower-tax jurisdictions. Tax incentives are generally not sufficient to attract major flows of investment. China is not a low-tax country, but rather a recipient of substantial foreign direct investment (FDI) inflows. The author examines whether this affects China’s international tax competitiveness. |
| Germany/United States – US Tax Reform: The Implications in a Germany-US Context
Author:Bärsch, S-E.; Olbert, M.; Spengel, C. Published online:26 June 2017 2017 (Volume 71), No. 6a/Special Issue Bulletin for International Taxation This article considers the implications of the US administration’s proposed tax reform, including a reduction in tax rates and a move to a territorial system of taxation, with regard to investment in the United States and for the financing, operating and tax planning policies of German and US multinational enterprises. |
| United States/European Union – The European Union and the United States: The Good Old Tax “Frenemies” in the Shadows of Reforms
Author:Pistone, P.; Brauner, Y. Published online:26 June 2017 2017 (Volume 71), No. 6a/Special Issue Bulletin for International Taxation In this article, the authors discuss the long-standing cooperation between the United States and the leading Member States of the European Union and comment on recent tax developments in these countries. |
| India/United States – US Tax Reform: The International Tax Implications for India – The “India-US Business Corridor”
Author:Wagh, S. Published online:26 June 2017 2017 (Volume 71), No. 6a/Special Issue Bulletin for International Taxation This article considers how investors in India and the United States will be affected by the US tax reform and whether the India-United States Income Tax Treaty (1989) will require revision. The emphasis is on the tax and economic implications of the US tax reform for the India-US business corridor. |
| Brazil/OECD – The Brazilian Transfer Pricing Regime
Author:Oliveira, A. Gomes de; Moreira, F. Lisboa Published online:25 May 2017 2017 (Volume 71), No. 6 Bulletin for International Taxation In this article, the authors outline the Brazilian transfer pricing regime and consider its implications as well as the importance of recent developments, notably the OECD/G20 Base Erosion and Profit Shifting initiative. |
| International/OECD – The Profit Split Method: Deciphering the OECD’s 2017 Discussion Draft
Author:Bilaney, S.K. Published online:10 August 2017 2017 (Volume 71), No. 9 Bulletin for International Taxation This article provides a critical overview of the OECD’s revised draft guidance of 2017 on the profit split method. In this context, the author suggests important ways in which to make the method more practical in its application |
| Turkey/OECD – New Advance Pricing Agreement Roll-Back Provisions in Turkey
Author:Erdem, T. Published online:10 August 2017 2017 (Volume 71), No. 9 Bulletin for International Taxation In this article, the author examines the new advance pricing agreement roll-back mechanism that has recently been introduced into the Turkish tax system, together with some other significant amendments to the Turkish transfer pricing rules. |
| Australia/United Kingdom/International – Australia’s New Diverted Profits Tax: The Rationale, the Expectations and the Unknowns
Author:Nguyen, H.K. (J.) Published online:10 August 2017 2017 (Volume 71), No. 9 Bulletin for International Taxation This article discusses the rationale, the elements, the expected outcomes and the concerns in relation to the introduction of the new diverted profits tax (DPT) in Australia. The DPT applies from 1 July 2017. |
| International/Uganda – An Analysis of the Oil Fiscal Regime of Uganda
Author:Kazi, W.B.; Beyeza, B. Published online:6 October 2017 2017 (Volume 71), No. 11 Bulletin for International Taxation This article analyses the oil fiscal regime of Uganda, taking into account its strengths and weaknesses in terms of its effectiveness and fiscal sustainability. The authors conclude that Uganda’s fiscal regime ensures that adequate oil revenues accrue to the government, while promoting oil sector investment, and fiscal and macroeconomic stability. |
| Mexico/OECD – The Influence of the OECD Multilateral Convention on Mexico’s Tax Treaties
Author:Becerra, J.A. Published online:4 September 2017 2017 (Volume 71), No. 10 Bulletin for International Taxation In this article, the author examines the influence of the OECD Multilateral Convention (MLI) with particular emphasis on the extent to which it will modify Mexico’s existing tax treaties and affect their interpretation and application as well as the relationship with its most important tax treaty partners. |
| International/OECD – The Transfer Pricing Aspects of Cross-Border Performance Guarantees
Author:Deshpande, G. Published online:28 June 2017 2017 (Volume 71), No. 7 Bulletin for International Taxation This article considers the transfer pricing aspects of cross-border performance guarantees and the various issues to which the payment of fees associated with such guarantees give rise. |
| Peru/OECD – Tax Reform in Peru: Adopting Anti-Base Erosion and Profit Shifting Measures with a View to Membership of the OECD and More
Author:Becerra O’Phelan, F. Published online:12 July 2017 2017 (Volume 71), No. 8 Bulletin for International Taxation In this article, the author examines the various provisions that have been introduced into Peruvian tax legislation with a view to Peru becoming an OECD member country, with special focus on the adoption of anti-base erosion and profit shifting measures. |
| International/European Union – Democracy, Revolution and Taxation
Author:Vanistendael, F.J.G.M. Published online:18 July 2017 2017 (Volume 71), No. 8 Bulletin for International Taxation In this article, the author addresses the potential impact of recent populist political events on liberal democracy by answering five key questions from the point of view of European and international tax law. |
| International/European Union/OECD – Adapting Current International Taxation to New Business Models: Two Proposals for the European Union
Author:Brauner, Y.; Pistone, P. Published online:5 October 2017 2017 (Volume 71), No. 12 Bulletin for International Taxation In this article, Yariv Brauner and Pasquale Pistone outline two solutions for the European Union to deal with the current problems facing international taxation: the virtual permanent establishment solution and the withholding tax solution. |
| International/OECD – The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)
Author:Groen, G. Published online:13 October 2017 2017 (Volume 71), No. 11 Bulletin for International Taxation In this article, the author considers the nature and scope of the mandatory arbitration provision in the OECD Multilateral Convention (2016) and discusses the effectiveness of the arbitration procedure. |