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45 Intertax 1 (2017)

handle is hein.kluwer/intrtax0045 and id is 1 raw text is: 




















Peer   Reviewed Article

2            Taxation of Individuals in the Sharing Economy
             Giorgio Beretta


Articles
12


What  Has Changed  in the Limitation on Benefits Clause of the 2016 US Model?:
Technical Modifications, Policy Considerations and Comparisons with Base
Erosion and Profit Shifting Action 6
Rita julien, Petra Koch & Rita Szudoczky


38           Redefining the Relation Between Articles 6, 7 and 21 of the OECD Model
             Alexander Bosman

49           Fair Taxation: Truth is in the Eye of the Beholder
             Paul B.W.L. Lamberts LL.M.

54           Qualification of Services Under Double Tax Treaties in Brazil: Open Issues After
             Iberdrola Case
             Leonardo Freitas de Moraes e Castro & Alexandre Luiz Moraes do Rigo Alonteiro

67           A Tax Law  Perspective of the 'Cooperation Council for the Arab States of the
             Gulf (the 'GCC')
             Roberto Scalia

82           Developments in the Analysis of the Tie-Breaker Rules for Individuals Under
             Article 4 (1) OECD
             Timothy Borg Olivier

103          Article Index

111          Author Index

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