This report summarizes the proceedings of the thirteenth assembly of the International Association of Tax Judges, which was held in The Hague, The Netherlands, on 8 and 9 September 2023.
{"title":"Report on the Proceedings of the Thirteenth Assembly of the International Association of Tax Judges Held in The Hague, The Netherlands, on 8 and 9 September 2023","authors":"B. Michel","doi":"10.59403/2g0154z","DOIUrl":"https://doi.org/10.59403/2g0154z","url":null,"abstract":"This report summarizes the proceedings of the thirteenth assembly of the International Association of Tax Judges, which was held in The Hague, The Netherlands, on 8 and 9 September 2023.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-07-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141647957","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The OECD’s and European Commission’s statistics for 2022 reveal important insights into the functioning of mutual agreement proceedings and a constant inventory of over 6,000 cases. German caseloads remain high, but stable. For Europe, the statistics show the growing importance of the EU Dispute Settlement Directive, but rather uncertain caseloads.
{"title":"Latest Statistics on OECD and EU Dispute Resolution Measures (Mutual Agreement and Arbitration Procedures) for 2022, with Emphasis on the Position in Germany","authors":"D. Liebchen, N. Strotkemper","doi":"10.59403/3bjz3pw","DOIUrl":"https://doi.org/10.59403/3bjz3pw","url":null,"abstract":"The OECD’s and European Commission’s statistics for 2022 reveal important insights into the functioning of mutual agreement proceedings and a constant inventory of over 6,000 cases. German caseloads remain high, but stable. For Europe, the statistics show the growing importance of the EU Dispute Settlement Directive, but rather uncertain caseloads.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-07-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141653134","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article examines the role of uncertainty arising from changes in transfer pricing regulations on the investment decisions of multinational enterprises. The authors’ findings highlight the significant effect of transfer pricing uncertainty and illustrate the importance of establishing international standards to enhance certainty.
{"title":"The Effect of Uncertainty Regarding Transfer Pricing Regulations and Administrative Practices on Corporate Investment Decisions","authors":"M. Azmi Shabestari, R. Safaei","doi":"10.59403/8cbkga","DOIUrl":"https://doi.org/10.59403/8cbkga","url":null,"abstract":"This article examines the role of uncertainty arising from changes in transfer pricing regulations on the investment decisions of multinational enterprises. The authors’ findings highlight the significant effect of transfer pricing uncertainty and illustrate the importance of establishing international standards to enhance certainty.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-07-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141662918","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article examines the tax legislation decision-making processes in European countries and the United States, noting similarities and differences in legislative initiative, constitutional review and citizen participation. These aspects of the legislative processes and other characteristics are analysed to assess their effect on the legitimacy of the tax system.
{"title":"The Legitimacy of Tax Law in Europe and the United States: Comparing Decision-Making Processes in Domestic Tax Law","authors":"T. Bathelt, P. Granell","doi":"10.59403/8rmxwa","DOIUrl":"https://doi.org/10.59403/8rmxwa","url":null,"abstract":"This article examines the tax legislation decision-making processes in European countries and the United States, noting similarities and differences in legislative initiative, constitutional review and citizen participation. These aspects of the legislative processes and other characteristics are analysed to assess their effect on the legitimacy of the tax system.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-06-04","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141266361","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In controlled foreign corporation rules, the adoption of the term “participation” both in the definition of control and in the ratable income inclusion rule may cause double taxation. The author considers these rules, and suggests a narrow interpretation of the term “participation” used in the ratable income inclusion rule as “entitlement to profits”.
{"title":"The Definition of Control in Controlled Foreign Corporation Rules and Double Taxation: Lessons from the Brazilian, US, EU and OECD Controlled Foreign Corporation Rules","authors":"A. P. Rausch","doi":"10.59403/11ajj0v","DOIUrl":"https://doi.org/10.59403/11ajj0v","url":null,"abstract":"In controlled foreign corporation rules, the adoption of the term “participation” both in the definition of control and in the ratable income inclusion rule may cause double taxation. The author considers these rules, and suggests a narrow interpretation of the term “participation” used in the ratable income inclusion rule as “entitlement to profits”.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-05-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141001553","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Profit shifting appears to be driven by underpriced group intangible sales to low-taxed affiliates derived from valuations resulting from income allocation methods. The enforcement of the periodic adjustment of the intangible price cannot definitively avoid this problem, but could (partly) avoid sales in breach of the arm’s length principle.
{"title":"Rules on Intangible Sales – The Real Problem with the Arm’s Length Principle","authors":"A. Musselli","doi":"10.59403/gjvn4q","DOIUrl":"https://doi.org/10.59403/gjvn4q","url":null,"abstract":"Profit shifting appears to be driven by underpriced group intangible sales to low-taxed affiliates derived from valuations resulting from income allocation methods. The enforcement of the periodic adjustment of the intangible price cannot definitively avoid this problem, but could (partly) avoid sales in breach of the arm’s length principle.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-05-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141000432","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In this article, the author considers Liquid Income Taxation-mv, Big Data Royalty-mv and Destination-Based Taxation in a dialogue regarding Professor R.S. Avi-Yonah’s 2023 Klaus Vogel lecture, which examined “The Past, Present and Future of Destination-Based Income Taxation”.
在本文中，作者就阿维-约纳（R.S. Avi-Yonah）教授 2023 年克劳斯-沃格尔（Klaus Vogel）讲座 "基于目的地的所得税的过去、现在和未来 "展开对话，探讨了流动所得税（Liquid Income Taxation-mv）、大数据版税（Big Data Royalty-mv）和基于目的地的所得税（Destination-Based Taxation）。
{"title":"Liquid Income Taxation-mv, Big Data Royalty-mv and Destination-Based Taxation: A Dialogue with Professor R.S. Avi-Yonah","authors":"M. Versiglioni","doi":"10.59403/1nsvk1p","DOIUrl":"https://doi.org/10.59403/1nsvk1p","url":null,"abstract":"In this article, the author considers Liquid Income Taxation-mv, Big Data Royalty-mv and Destination-Based Taxation in a dialogue regarding Professor R.S. Avi-Yonah’s 2023 Klaus Vogel lecture, which examined “The Past, Present and Future of Destination-Based Income Taxation”.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-04-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140668993","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article considers global developments with regard to sovereign wealth funds. It approaches this subject generally, and then examines the topic with specific reference to the United Arab Emirates (UAE) and the provisions in the tax treaties that the UAE have concluded.
{"title":"Worldwide Developments Regarding Sovereign Wealth Funds in General and the Specific Example of the United Arab Emirates and Its Tax Treaties","authors":"G. Mazzoni","doi":"10.59403/34ceqfd","DOIUrl":"https://doi.org/10.59403/34ceqfd","url":null,"abstract":"This article considers global developments with regard to sovereign wealth funds. It approaches this subject generally, and then examines the topic with specific reference to the United Arab Emirates (UAE) and the provisions in the tax treaties that the UAE have concluded.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-04-11","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140713627","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article contrasts lithium royalty systems in Western Australia (WA) and Quebec, emphasizing royalty taxation as a significant cost. It contrasts Quebec’s efficient, long-term economic approach against WA’s less competitive regime, mitigated by high lithium demand. The article suggests that Quebec’s model is a viable blueprint for sustainable royalty taxation.
{"title":"Powering the Future: Lithium Royalty Taxation and the Renewable Energy Revolution – A Legal and Economic Comparison of Western Australia and Quebec","authors":"J. Feinberg","doi":"10.59403/zaj0e6","DOIUrl":"https://doi.org/10.59403/zaj0e6","url":null,"abstract":"This article contrasts lithium royalty systems in Western Australia (WA) and Quebec, emphasizing royalty taxation as a significant cost. It contrasts Quebec’s efficient, long-term economic approach against WA’s less competitive regime, mitigated by high lithium demand. The article suggests that Quebec’s model is a viable blueprint for sustainable royalty taxation.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-04-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140729529","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"Editorial Note","authors":"J. Hattingh, M. Hammer","doi":"10.59403/1q8hgde","DOIUrl":"https://doi.org/10.59403/1q8hgde","url":null,"abstract":"In this note, the editors of the Bulletin for International Taxation introduce the summary report on the Farewell Seminar in Honour of Wim Wijnen.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2024-04-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140762769","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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