In these comments, Stewart Brant responds to Professor Reuven Avi-Yonah’s Klaus Vogel Lecture for 2023 on the history of, the current state of affairs regarding and the prospects for destination-based income taxation.
{"title":"Comments on the Klaus Vogel Lecture 2023: The Past, Present and Future of Destination-Based Income Taxation","authors":"S. Brant","doi":"10.59403/22hf8bv","DOIUrl":"https://doi.org/10.59403/22hf8bv","url":null,"abstract":"In these comments, Stewart Brant responds to Professor Reuven Avi-Yonah’s Klaus Vogel Lecture for 2023 on the history of, the current state of affairs regarding and the prospects for destination-based income taxation.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"70 6","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"140505799","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 commences by outlining the challenges faced by developing countries in the transfer pricing of marketing and distribution activities by reflecting on relevant case law. It then evaluates the concerns associated with the existing design of Amount B and proposes solutions to maximize the Amount B for developing countries.
本文首先通过对相关判例法的反思，概述了发展中国家在营销和分销活动转让定价方面面临的挑战。然后，文章评估了与现行 B 额设计相关的问题，并提出了为发展中国家最大限度地提高 B 额的解决方案。
{"title":"Maximizing Amount B of the OECD’s Pillar One for Developing Countries","authors":"S. Kale, M. Shi","doi":"10.59403/3z4z8t7","DOIUrl":"https://doi.org/10.59403/3z4z8t7","url":null,"abstract":"This article commences by outlining the challenges faced by developing countries in the transfer pricing of marketing and distribution activities by reflecting on relevant case law. It then evaluates the concerns associated with the existing design of Amount B and proposes solutions to maximize the Amount B for developing countries.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":" 48","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-09","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139640509","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 the categorization of the income earned by influencers in relation to tax treaties, with specific reference to the allocation of such income to articles 7, 12 and 17 of the OECD Model.
{"title":"Influencer Income and Tax Treaties","authors":"S. Kostikidis","doi":"10.59403/s06fdk","DOIUrl":"https://doi.org/10.59403/s06fdk","url":null,"abstract":"This article considers the categorization of the income earned by influencers in relation to tax treaties, with specific reference to the allocation of such income to articles 7, 12 and 17 of the OECD Model.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"4 2","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-05-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141203120","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 arguments for taxing capital gains derived in Brazil from the indirect sale of shares in Brazilian resident companies by non-residents and how such a situation could be brought about.
{"title":"Taxation of Capital Gains on Indirect Sales of Shares of Brazilian Companies by Non-Residents: The Allocation of Taxing Rights or Tax Avoidance Schemes?","authors":"I. G. Calich da Fonseca","doi":"10.59403/1xanwqw","DOIUrl":"https://doi.org/10.59403/1xanwqw","url":null,"abstract":"In this article, the author examines the arguments for taxing capital gains derived in Brazil from the indirect sale of shares in Brazilian resident companies by non-residents and how such a situation could be brought about.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"54 16","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-05-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141204273","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 outlines the significant measures taken by the national governments and tax authorities of five major Latin American jurisdictions due to the COVID-19 pandemic. Emphasis is placed on measures that may affect international or cross-border tax structures, reduce tax liabilities or improve cash flow by deferring payment.
{"title":"COVID-19 Tax Measures in Five Major Latin American Jurisdictions","authors":"R. B. D. Sousa","doi":"10.59403/ygn21c","DOIUrl":"https://doi.org/10.59403/ygn21c","url":null,"abstract":"This article outlines the significant measures taken by the national governments and tax authorities of five major Latin American jurisdictions due to the COVID-19 pandemic. Emphasis is placed on measures that may affect international or cross-border tax structures, reduce tax liabilities or improve cash flow by deferring payment.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"42 26","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-05-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141204611","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 OECD/G20 programme of work dealing with the tax challenges arising from the digitalization of the economy, highlights the partial abandonment of the arm’s length principle, discusses two ways of minimum taxation, evaluates the obstacles to international tax coordination and considers the possible consequences for national tax policy.
{"title":"Remarks on the Future Prospects of the OECD/G20 Programme of Work – Profit Allocation (Pillar One) and Minimum Taxation (Pillar Two)","authors":"U. Schreiber","doi":"10.59403/cjwvkg","DOIUrl":"https://doi.org/10.59403/cjwvkg","url":null,"abstract":"This article examines the OECD/G20 programme of work dealing with the tax challenges arising from the digitalization of the economy, highlights the partial abandonment of the arm’s length principle, discusses two ways of minimum taxation, evaluates the obstacles to international tax coordination and considers the possible consequences for national tax policy.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"15 12","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-05-13","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141205245","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 surveys the tax measures that China has implemented in response to the crisis caused by the COVID-19 pandemic. In this context, the author pays special attention to the tax incentives that are intended to protect people’s livelihoods and to promote economic recovery.
{"title":"The Implications of China’s Fiscal Measures Relating to the COVID-19 Pandemic","authors":"Diheng Xu","doi":"10.59403/1egacvb","DOIUrl":"https://doi.org/10.59403/1egacvb","url":null,"abstract":"This article surveys the tax measures that China has implemented in response to the crisis caused by the COVID-19 pandemic. In this context, the author pays special attention to the tax incentives that are intended to protect people’s livelihoods and to promote economic recovery.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"37 24","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-05-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141206338","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 is causing a health crisis and a decline in economic activity, forcing governments to take unprecedented measures. According to the IMF, Germany is one of the world leaders in terms of spending to mitigate the related economic consequences. This article provides an overview of the main tax and fiscal policy measures in Germany as well as the related effects on financial decision-making.
{"title":"Tax and Fiscal Policy Measures in Response to the COVID-19 Crisis – Overview and Economic Analysis for Germany","authors":"S. Weber","doi":"10.59403/w28t3t","DOIUrl":"https://doi.org/10.59403/w28t3t","url":null,"abstract":"COVID-19 is causing a health crisis and a decline in economic activity, forcing governments to take unprecedented measures. According to the IMF, Germany is one of the world leaders in terms of spending to mitigate the related economic consequences. This article provides an overview of the main tax and fiscal policy measures in Germany as well as the related effects on financial decision-making.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"70 12","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-04-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141209722","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 Special Issue of the Bulletin for International Taxation contains a series of articles prepared further to the two-day interdisciplinary conference organized in Lausanne on 19-20 December 2019 by the Max Planck Institute for Tax Law and Public Finance and the Tax Policy Center of the University of Lausanne. This foreword describes the background, purpose and structure of the conference as well as its main objectives, and presents the articles of this Special Issue.
本期《国际税务公报》特刊收录了马克斯-普朗克税法与公共财政研究所（Max Planck Institute for Tax Law and Public Finance）和洛桑大学税收政策中心（Tax Policy Center of the University of Lausanne）于 2019 年 12 月 19-20 日在洛桑举办的为期两天的跨学科会议的后续文章。本前言介绍了会议的背景、目的和结构及其主要目标，并介绍了本特刊的文章。
{"title":"Foreword: Tax Treaty Interpretation after BEPS","authors":"R. Danon, W. Schön","doi":"10.59403/3nvsvhd","DOIUrl":"https://doi.org/10.59403/3nvsvhd","url":null,"abstract":"This Special Issue of the Bulletin for International Taxation contains a series of articles prepared further to the two-day interdisciplinary conference organized in Lausanne on 19-20 December 2019 by the Max Planck Institute for Tax Law and Public Finance and the Tax Policy Center of the University of Lausanne. This foreword describes the background, purpose and structure of the conference as well as its main objectives, and presents the articles of this Special Issue.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":" 6","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-03-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141220169","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 effect of the preamble of tax treaties before and after the amendments made to the OECD Model (2017) on the interpretation of tax treaties with the aim of preventing their abuse.
{"title":"Role of the Preamble for the Interpretation of Old and New Tax Treaties and on the Policy of the Prevention of Treaty Abuse","authors":"De Broe","doi":"10.59403/3ceqp6z","DOIUrl":"https://doi.org/10.59403/3ceqp6z","url":null,"abstract":"This article examines the effect of the preamble of tax treaties before and after the amendments made to the OECD Model (2017) on the interpretation of tax treaties with the aim of preventing their abuse.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":" 2","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-03-29","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141220185","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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