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https://shop.ibfd.org/journal/foreign-investment-funds-change-tax-regime-dividends-and-capital-gains Foreign Investment Funds: Change in Tax Regime for Dividends and Capital Gains | IBFD The present article aims to analyse the impact of the 2021 legislative changes concerning the taxation regime for dividends and capital gains applicable to... foreign investment funds https://shop.ibfd.org/journal/pro-rata-deduction-entities-established-several-vat-jurisdictions Pro Rata Deduction by Entities Established in Several VAT Jurisdictions | IBFD The principles for determining proportional deduction of VAT (pro rata) by legal entities that are established in more than one VAT jurisdiction give rise to... pro rata deduction entities https://shop.ibfd.org/journal/shift-burden-proof-regard-transfer-pricing The Shift in the Burden of Proof in regard to Transfer Pricing | IBFD In this note, the author discusses the development of the transfer pricing regime in Italy in the context of recent legislative and case law developments that,... burden of proof the shift transfer pricing https://shop.ibfd.org/journal/taxing-digital-businesses-australia Taxing Digital Businesses in Australia | IBFD In this issue of the Asia-Pacific Tax Bulletin we have curated a series of country reports taking a look at the direct and indirect taxation measures adopted... businesses in australia taxing digital ibfd https://rss.globenewswire.com/news-release/2021/06/01/2239234/0/en/IBFD-releases-new-Transfer-Pricing-Tables.html IBFD releases new Transfer Pricing Tables IBFD is offering a not-to-be-missed free product trial to its entire TP collection... new transfer ibfd releases pricing tables https://shop.ibfd.org/journal/location-savings-indonesia Location Savings in Indonesia | IBFD In this article, the authors describe the concept of location savings and the position taken by the Indonesian tax authorities. in indonesia location savings ibfd https://shop.ibfd.org/journal/straight-through-processing-difficulties-applying-royalties-article-oecd-model Straight-Through Processing: Difficulties in Applying the Royalties Article of the OECD Model | IBFD This article analyses the 2008 updated royalties article of the OECD Model Tax Convention on payments with regard to straight-through processing arrangements... straight through processing https://shop.ibfd.org/journal/singapore-stamp-duty-strengthening-additional-conveyance-duty-rules Singapore Stamp Duty: Strengthening the Additional Conveyance Duty Rules | IBFD Additional conveyance duty (ACD) is a tax that was introduced in 2017 on the sale of shares in property-heavy companies, with the aim of cooling the property... stamp duty singapore strengthening additional conveyance https://shop.ibfd.org/journal/court-denies-tax-treaty-benefits-long-borrower-swiss-shares Court Denies Tax Treaty Benefits to Long Borrower of Swiss Shares | IBFD The Swiss Federal Administrative Court upheld a decision by the Federal Tax Administration to reject the tax treaty-based partial refund claims of a Luxembourg... tax treaty https://shop.ibfd.org/journal/nexus-taxation-asia-contemporary-permanent-establishment-and-related-issues-japan Nexus for taxation in Asia : contemporary permanent establishment and related issues : Japan | IBFD Country report dealing with nexus for income taxation of foreign (non-resident) corporations, nexus for taxation of the compensation of non-resident... https://www.ibfd.org/ Home | IBFD ibfd https://shop.ibfd.org/journal/international-tax-considerations-0 International tax considerations | IBFD The author describes the international tax considerations surrounding Chinese inbound and outbound investments. international tax considerations ibfd https://shop.ibfd.org/journal/characterization-other-states-partnerships-income-tax Characterization of other states' partnerships for income tax | IBFD The OECD Partnership Report is a significant contribution to the discussion of how to treat partnerships for tax treaty purposes when two states categorize a... other states income tax characterization partnerships ibfd https://shop.ibfd.org/journal/tax-treatment-cross-border-income-derived-through-partnership-finnish-perspective Tax treatment of cross-border income derived through a partnership - a Finnish perspective | IBFD Cross-border investment or business may be carried out through an entity having the legal form of a partnership. The use of partnerships for cross-border... https://shop.ibfd.org/journal/tax-convergence-and-next-generation-european-union Tax Convergence and the Next Generation European Union | IBFD In this article, the author describes the spontaneous convergence of COVID-related tax measures that occurred in 2020, which was closely followed, at the EU... the next generation european union tax convergence ibfd https://shop.ibfd.org/journal/transactions-between-main-offices-and-their-fixed-establishments Transactions between main offices and their fixed establishments | IBFD Usually, little or no information is available on the progress, or lack of progress, made in the process of getting Proposals for Directives, amending the EU... main offices transactions fixed establishments ibfd https://shop.ibfd.org/journal/explanation-2009-irs-cost-sharing-arrangement-regulations An Explanation of the 2009 IRS Cost Sharing Arrangement Regulations | IBFD New Temporary Regulations were issued in 2009 under Sec. 482 with regard to cost sharing arrangements. This article aims to reduce the complexity of the... an explanation of the cost sharing https://shop.ibfd.org/journal/comparative-analysis-amended-netherlands-tax-loss-relief-rules A Comparative Analysis of the Amended Netherlands Tax Loss Relief Rules | IBFD In this article, the author analyses and compares the loss carry-over rules in the Netherlands, Germany, France and the United Kingdom. comparative analysis of the https://shop.ibfd.org/journal/retroactive-effect-mergers-under-luxembourg-tax-law-time-travel-actually-possible Retroactive Effect of Mergers under Luxembourg Tax Law: Is Time Travel Actually Possible? | IBFD In this note, the authors discuss the circumstances in which a merger between domestic companies in Luxembourg might be given retroactive effect. To the extent... https://shop.ibfd.org/journal/how-reform-taxation-corporate-groups-europe How to Reform Taxation of Corporate Groups in Europe | IBFD There are at least two reasons why taxation of corporate groups in Europe calls for reform. Firstly, differences are to be found between the tax treatment of a... how to corporate groups in europe reform taxation https://shop.ibfd.org/journal/tax-practice-cost-plus-method-often-tnmm-disguise-what-do-about-it In tax practice the cost-plus method is often a TNMM in disguise : what to do about it? | IBFD The author discusses whether transfer pricing methods that are in practice referred to as cost-plus methods are in fact applications of the transactional net... https://shop.ibfd.org/journal/canada-revenue-agency-reports-its-apa-programme-2007-2008 Canada Revenue Agency Reports on Its APA Programme for 2007-2008 | IBFD This article provides an overview of the current state of the APA programme in Canada. Topics considered include reports on the APA programme issued by the... canada revenue agency https://shop.ibfd.org/journal/impact-beps-multilateral-instrument-international-tax-policies The Impact of the BEPS Multilateral Instrument on International Tax Policies | IBFD This article assesses the impact of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting by... the impact international tax beps multilateral https://shop.ibfd.org/journal/contemporary-transfer-pricing-case-law-finnish-supreme-administrative-court Contemporary Transfer Pricing Case Law of the Finnish Supreme Administrative Court | IBFD This article examines recent transfer pricing case law of the Supreme Administrative Court. It provides an analysis of four key decisions given between 2010... transfer pricing case law of the https://shop.ibfd.org/journal/developments-new-zealandphilippines-details-protocol Developments: New Zealand/Philippines: Details of Protocol | IBFD new zealand developments philippines details protocol https://shop.ibfd.org/journal/taxation-mergers-and-acquisitions-japan-including-cross-border-triangular-mergers Taxation of mergers and acquisitions in Japan, including cross-border triangular mergers | IBFD Japan's corporation tax laws introduced the first modern tax provisions for mergers, acquisitions and restructurings in the tax reform of 2001. Thereafter,... mergers and acquisitions in japan https://shop.ibfd.org/journal/cross-border-vat-groupings-effects-new-italian-regulation Cross-Border VAT Groupings: The Effects of the New Italian Regulation | IBFD Italian Law No. 232/2016 provides for VAT groupings in accordance with article 11 of the VAT Directive (2006/112). In considering a group of companies as a... cross border the effects vat groupings https://shop.ibfd.org/journal/taxing-time-cryptocurrencies Taxing Time for Cryptocurrencies | IBFD Regulators in many countries, including India, view cryptocurrencies as a combination of a bubble and a Ponzi scheme. The Reserve Bank of India has taken steps... taxing time cryptocurrencies ibfd https://shop.ibfd.org/journal/year-end-adjustments-and-globe-implications-italian-and-us-perspectives Year-End Adjustments and GloBE Implications: Italian and US Perspectives | IBFD This article examines the treatment of year-end transfer pricing adjustments under the GloBE rules, comparing Italian and US approaches and highlighting the... year end adjustments globe implications italian https://shop.ibfd.org/journal/transfer-pricing-aspects-intra-group-financial-guarantees-light-beps-action-plan Transfer Pricing Aspects of Intra-Group Financial Guarantees in Light of the BEPS Action Plan | IBFD The main objective of this article is to provide an overview of the transfer pricing aspects of intra-group financial guarantees. It discusses the current... https://shop.ibfd.org/journal/reform-swiss-vat-vat-act-2010 Reform of Swiss VAT - the VAT Act from 2010 | IBFD Switzerland is about to implement the biggest reform in the field of VAT since the introduction of the tax in 1995. The new VAT Act 2009, which is envisaged to... the act reform swiss vat ibfd https://shop.ibfd.org/journal/retirement-funds-and-vat Retirement funds and VAT | IBFD This article describes some VAT aspects of institutions established for occupational retirement provision, or "retirement funds". The author briefly examines... retirement funds vat ibfd https://shop.ibfd.org/journal/developments-vietnam-tax-incentives-announced Developments: Vietnam: Tax Incentives Announced | IBFD tax incentives developments vietnam announced ibfd https://shop.ibfd.org/journal/us-update-1 US Update | IBFD This is the third in a regular series of articles that examines recent significant developments regarding US tax matters as these relate to international... us update ibfd https://shop.ibfd.org/journal/developments-china-exemption-withholding-tax-dividends-be-abolished Developments: China: Exemption of Withholding Tax on Dividends to Be Abolished | IBFD withholding tax https://shop.ibfd.org/journal/new-guideline-recognition-transparency-principle-foreign-partnerships New guideline on recognition of transparency principle for foreign partnerships | IBFD On 29 March 2007, the French tax administration issued a Guideline on the application of tax treaties to French-source passive income received via foreign... on recognition new guideline https://www.marshallislandbusinessdigest.com/article/845674855-blue-j-and-ibfd-unveil-ai-platform-for-instant-cross-border-tax-research Blue J and IBFD Unveil AI Platform for Instant Cross-Border Tax Research | Marshall Island Business... https://shop.ibfd.org/journal/tax-treatment-currency-swap-payments-received-non-residents-spain Tax treatment of currency swap payments received by non-residents : Spain | IBFD Part of a comparative survey containing an in-depth description of the tax and accounting treatment of currency swap payments and deal with critical... tax treatment currency swap https://shop.ibfd.org/journal/update-financial-transaction-tax Update on Financial Transaction Tax | IBFD The author discusses the most recent developments in the implementation and continued, but still incomplete to a large extent, clarification of the Italian... financial transaction tax update ibfd https://shop.ibfd.org/journal/developments-malaysia-budget-2005 DEVELOPMENTS: MALAYSIA: BUDGET FOR 2005 | IBFD developments malaysia budget ibfd https://shop.ibfd.org/journal/tax-treaty-treatment-dividend-related-payments-under-share-loan-agreements Tax Treaty Treatment of Dividend Related Payments under Share Loan Agreements | IBFD The article analyses some of the qualification and allocation challenges that dividend related payments under share loan agreements give rise to for tax treaty... tax treaty https://shop.ibfd.org/journal/thailand-tax-treatment-capital-expenditure Thailand : tax treatment of capital expenditure | IBFD Capital expenditure raises a number of issues, such as what it includes, whether it can be deducted, restrictions on amortization, and recapture upon ultimate... tax treatment capital expenditure thailand ibfd https://shop.ibfd.org/journal/vat-fraud-south-african-experience VAT fraud : the South African experience | IBFD Analysis of the different facets of VAT fraud in South Africa and the means used by the Revenue Service to mitigate VAT leakage. the south african vat fraud experience ibfd https://shop.ibfd.org/journal/treatment-ai-powered-services-under-european-vat The Treatment of AI-Powered Services under European VAT | IBFD Artificial intelligence (AI) is transforming digital service delivery across content creation, customer support, legal analysis, and medical diagnostics.... the treatment ai powered european vat services ibfd https://shop.ibfd.org/journal/taxation-crimes-australia-and-commissioners-prosecution-policy Taxation crimes in Australia and the Commissioner's prosecution policy | IBFD The nature of tax crimes in Australia and the criteria used in considering criminal prosecution are discussed. in australia and the prosecution policy taxation crimes https://shop.ibfd.org/journal/ifa-congress-japan-last An IFA Congress in Japan - at last! | IBFD ifa congress in japan at last ibfd https://shop.ibfd.org/journal/portuguese-debra-example-follow Is the Portuguese DEBRA an Example to Follow? | IBFD In this article, the author examines the Portuguese debt-equity bias reduction allowance (DEBRA) regime and whether or not it might be of interest in... is the an example to follow portuguese debra https://shop.ibfd.org/journal/cfe-forum-2015-tax-governance-and-tax-risk-management-post-beps-world CFE Forum 2015: Tax Governance and Tax Risk Management in a Post-BEPS World | IBFD In this note the authors provide a summary of the presentations made at the CFE Forum 2015 held in Brussels on 26 March 2015. https://shop.ibfd.org/journal/development-taxation-nepal Development of taxation in Nepal | IBFD The author examines the history of Nepalese taxation and the changing structure of different taxes, and then looks at current issues and recommends... development taxation nepal ibfd https://shop.ibfd.org/journal/taxation-dividends Taxation of dividends | IBFD Discussion on the main changes to Russian corporate tax laws and tax laws as a result of the Law on Joint Stock Companies of 31 October 2002, as well as some... taxation of dividends ibfd https://shop.ibfd.org/journal/new-law-amends-transfer-pricing-documentation-rules-and-apa-procedure New Law Amends Transfer Pricing Documentation Rules and APA Procedure | IBFD The Greek parliament has amended the Tax Procedure Code to bring the rules regarding transfer pricing documentation and APA procedures in line with... new law transfer pricing amends https://shop.ibfd.org/journal/developments-malaysia-package-measures-stimulate-economic-growth DEVELOPMENTS: MALAYSIA: PACKAGE OF MEASURES TO STIMULATE ECONOMIC GROWTH | IBFD economic growth developments malaysia package measures https://shop.ibfd.org/journal/vat-implications-buying-residential-property-south-africa VAT implications of buying residential property in South Africa | IBFD Examines the VAT implications of residential property transactions from the perspective of the purchaser. in south africa residential property vat implications buying https://shop.ibfd.org/journal/unintended-tax-effects-functional-currency-reporting Unintended tax effects of functional currency reporting | IBFD Addresses, among others, the impact of functional currency corporate income tax reporting on certain Netherlands dividend withholding tax and capital tax... tax effects functional currency reporting https://www.ibfd.org/news/ibfd-statement-ukraine IBFD Statement on Ukraine | IBFD We stand with our colleagues and their loved ones who are personally affected by the conflict. ibfd statement ukraine https://shop.ibfd.org/journal/tax-treatment-stock-options-and-financial-entities Tax treatment of stock options and financial entities | IBFD The tax treatment of stock options, and relating to the establishment of bank holding companies, special purpose companies and securities investments trusts,... tax treatment stock options financial entities ibfd https://shop.ibfd.org/journal/european-court-justice-recent-developments European Court of Justice : recent developments | IBFD In this article, the editors provide an overview of the VAT judgments of the Court of Justice of the European Union (ECJ) and opinions of the Advocates General... european court of justice recent developments ibfd https://shop.ibfd.org/journal/rethinking-design-australias-cfc-rules-global-economy Rethinking the design of Australia's CFC rules in the global economy | IBFD The introduction of controlled foreign company (CFC) rules has come in two "waves". The "pre-globalization wave" saw CFC rules introduced in the United States... the design https://shop.ibfd.org/journal/value-added-tax-norway Value added tax in Norway | IBFD Description of the VAT system in Norway, originally introduced in 1970, and comparison with the EU VAT system. Discussion of the sources and structure of... value added tax in norway ibfd https://shop.ibfd.org/journal/update-beps-and-fatca Update on BEPS and FATCA | IBFD New Zealand is actively involved in reviewing its domestic legislation in light of the various BEPS Actions, and has concluded an intergovernmental agreement... update beps fatca ibfd https://shop.ibfd.org/journal/withholding-tax-dividends-montenegro Withholding Tax on Dividends in Montenegro | IBFD In this note, the author briefly outlines the adverse tax implications of holding structures in Montenegro as provided for by the Montenegrin Corporate Income... withholding tax dividends montenegro ibfd https://shop.ibfd.org/journal/oil-speculation-tax-discusssion-draft-roils-markets Oil speculation tax discusssion draft roils the markets | IBFD This article discusses the Wyden-Grassley discussion draft of legislation that would change the taxation of trading and investing in oil and gas commodities.... the markets oil speculation tax draft https://shop.ibfd.org/journal/true-reverse-charge-germany The "true" reverse charge in Germany | IBFD According to the provisions of the Sixth VAT Directive, Germany should have introduced a reverse charge mechanism more than twenty years ago. After two decades... reverse charge in germany true ibfd