In this article, the author reports on the Farewell Seminar, entitled “Tax Treaties – What Are We Going to Do with Them?” held under the auspices of the IBFD, Amsterdam, for Professor Wim Wijnen on the occasion of his retirement.
{"title":"A Farewell Seminar in Honour of Wim Wijnen: Tax Treaties – What Are We Going to Do with Them?","authors":"F, De Lillo","doi":"10.59403/23nnqs3","DOIUrl":"https://doi.org/10.59403/23nnqs3","url":null,"abstract":"In this article, the author reports on the Farewell Seminar, entitled “Tax Treaties – What Are We Going to Do with Them?” held under the auspices of the IBFD, Amsterdam, for Professor Wim Wijnen on the occasion of his retirement.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"24 13","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-03-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140372745","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 taxation that will be implemented through GloBE Pillar Two domestically in South Africa. Based on analysis of the annual financial statements, the author explores the impact on the global effective rate of corporate tax paid by multinational enterprises headquartered in South Africa.
{"title":"A Proposal on How to Implement GloBE Pillar Two in South Africa","authors":"A. Futter","doi":"10.59403/3ve4swx","DOIUrl":"https://doi.org/10.59403/3ve4swx","url":null,"abstract":"This article examines the taxation that will be implemented through GloBE Pillar Two domestically in South Africa. Based on analysis of the annual financial statements, the author explores the impact on the global effective rate of corporate tax paid by multinational enterprises headquartered in South Africa.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"39 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-03-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140234459","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 GloBE Model Rules on Pillar Two contain certain specific definitions of permanent establishments, which apply depending on the features of the foreign place of business of a given enterprise. The definitions refer to treaty law, but the meaning and the effect of those references are not always entirely clear.
{"title":"Interpretative Issues Arising from the Definitions of Permanent Establishments under the GloBE Model Rules","authors":"G.F. Patti","doi":"10.59403/1rcq0sf","DOIUrl":"https://doi.org/10.59403/1rcq0sf","url":null,"abstract":"The GloBE Model Rules on Pillar Two contain certain specific definitions of permanent establishments, which apply depending on the features of the foreign place of business of a given enterprise. The definitions refer to treaty law, but the meaning and the effect of those references are not always entirely clear.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"54 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-02-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140424209","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 Qualified Domestic Minimum Top-up Tax (QDMTT) is presented as the preferred choice for developing countries. However, given its unfamiliar design, complexity, limited revenue gain, peer review and resource burdens, the QDMTT is unsuitable for developing countries. Instead, such countries should reform their tax incentives, and consider an across-the-board minimum tax.
{"title":"Qualified Domestic Minimum Top-Up Tax: Should Developing Countries Adopt It?","authors":"R.R. Das","doi":"10.59403/1mx1cke","DOIUrl":"https://doi.org/10.59403/1mx1cke","url":null,"abstract":"The Qualified Domestic Minimum Top-up Tax (QDMTT) is presented as the preferred choice for developing countries. However, given its unfamiliar design, complexity, limited revenue gain, peer review and resource burdens, the QDMTT is unsuitable for developing countries. Instead, such countries should reform their tax incentives, and consider an across-the-board minimum tax.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"26 23","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-02-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140450240","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 December 2022, the UN General Assembly adopted Resolution A/RES/77/244 on the promotion of inclusive and effective international tax cooperation. Moreover, Tax Report 2023 may institute an intergovernmental tax body providing for legally binding guidelines for national tax systems. This article considers the chances for such international tax cooperation.
{"title":"Shaping the UN’s Future Role in International Tax Cooperation: Resolution A/RES/77/244 and the Options Raised in Tax Report 2023 as an Opening for Legally Binding Tax-Norm Setting by the UN","authors":"S. Greil, M. Kockrow","doi":"10.59403/37tfeet","DOIUrl":"https://doi.org/10.59403/37tfeet","url":null,"abstract":"In December 2022, the UN General Assembly adopted Resolution A/RES/77/244 on the promotion of inclusive and effective international tax cooperation. Moreover, Tax Report 2023 may institute an intergovernmental tax body providing for legally binding guidelines for national tax systems. This article considers the chances for such international tax cooperation.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"90 2","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-02-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139858829","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 December 2022, the UN General Assembly adopted Resolution A/RES/77/244 on the promotion of inclusive and effective international tax cooperation. Moreover, Tax Report 2023 may institute an intergovernmental tax body providing for legally binding guidelines for national tax systems. This article considers the chances for such international tax cooperation.
{"title":"Shaping the UN’s Future Role in International Tax Cooperation: Resolution A/RES/77/244 and the Options Raised in Tax Report 2023 as an Opening for Legally Binding Tax-Norm Setting by the UN","authors":"S. Greil, M. Kockrow","doi":"10.59403/37tfeet","DOIUrl":"https://doi.org/10.59403/37tfeet","url":null,"abstract":"In December 2022, the UN General Assembly adopted Resolution A/RES/77/244 on the promotion of inclusive and effective international tax cooperation. Moreover, Tax Report 2023 may institute an intergovernmental tax body providing for legally binding guidelines for national tax systems. This article considers the chances for such international tax cooperation.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"343 4","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-02-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139799222","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 examines the implications of the Subject to Tax Rule (STTR) of the OECD’s Pillar Two for developing countries. He argues that the STTR is unreasonably complex, and will not be advantageous for developing countries. Accordingly, developing countries should be very cautious in adopting the STTR.
{"title":"Earth to OECD: You Must Be Joking – The Subject to Tax Rule of Pillar Two","authors":"B.J. Arnold","doi":"10.59403/3j8ntgs","DOIUrl":"https://doi.org/10.59403/3j8ntgs","url":null,"abstract":"In this article, the author examines the implications of the Subject to Tax Rule (STTR) of the OECD’s Pillar Two for developing countries. He argues that the STTR is unreasonably complex, and will not be advantageous for developing countries. Accordingly, developing countries should be very cautious in adopting the STTR.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"180 5","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-31","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140475487","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 “object and purpose” of a tax treaty by discussing its meaning, identification and relevance based on the Vienna Convention (1969). It proposes an interpretation of the principal purpose test rule that remains within the limits of treaty wording while giving priority to the object and purpose.
{"title":"The Concept of the “Object and Purpose” in Tax Treaty Law Based on the Vienna Convention (1969) and the Principal Purposes Test Rule","authors":"K. Dziurdź","doi":"10.59403/11fvrdd","DOIUrl":"https://doi.org/10.59403/11fvrdd","url":null,"abstract":"This article examines the “object and purpose” of a tax treaty by discussing its meaning, identification and relevance based on the Vienna Convention (1969). It proposes an interpretation of the principal purpose test rule that remains within the limits of treaty wording while giving priority to the object and purpose.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"14 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-29","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140489295","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}
COVID-19 had a huge effect on African countries. It revealed how vulnerable African tax systems are to a massive global economic shock. This article explores what made the tax systems for individuals in African countries more vulnerable than other jurisdictions, and what reforms should be made to address such vulnerabilities.
{"title":"The COVID-19 Pandemic and the Taxation of Individuals in Africa: Proposals for Reform","authors":"A. Titus","doi":"10.59403/3kn94g6","DOIUrl":"https://doi.org/10.59403/3kn94g6","url":null,"abstract":"COVID-19 had a huge effect on African countries. It revealed how vulnerable African tax systems are to a massive global economic shock. This article explores what made the tax systems for individuals in African countries more vulnerable than other jurisdictions, and what reforms should be made to address such vulnerabilities.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"424 2","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140502512","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}
A significant obstacle to the unilateral adoption of the OECD’s Pillar One are tax treaties since many countries cannot override tax treaties unilaterally. In his Klaus Vogel Lecture for 2023, Professor Reuven Avi-Yonah asks what are the chances for adopting a true multilateral convention for income taxation?
{"title":"Klaus Vogel Lecture 2023: The Past, Present and Future of Destination-Based Income Taxation","authors":"R. Avi-Yonah","doi":"10.59403/2q3nwnr","DOIUrl":"https://doi.org/10.59403/2q3nwnr","url":null,"abstract":"A significant obstacle to the unilateral adoption of the OECD’s Pillar One are tax treaties since many countries cannot override tax treaties unilaterally. In his Klaus Vogel Lecture for 2023, Professor Reuven Avi-Yonah asks what are the chances for adopting a true multilateral convention for income taxation?","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"47 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-17","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140505293","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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