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"Everything you see exists together in a delicate balance … and so we are all connected in the great Circle of Life," Mufasa once told his young cub in The Lion King.

Peter Nias, barrister and Centre of Effective Dispute Resolution (CEDR) panel mediator of Pump Court Tax Chambers in the UK, considers whether the arbitration provisions in the OECD’s Multilateral Instrument (MLI) and Action 14 proposals offer the only option for dispute resolution for all parties.

A suite of mutually reinforcing measures with an overall focus on resolution at the earliest point in time is the ultimate goal for taxpayers and tax authorities. Achim Pross, Sandra Knaepen and Mark Johnson of the OECD describe the organisation’s comprehensive dispute resolution agenda, both within and beyond the BEPS project.

For the past couple of years, many commentators have used the term “disruption,” sometimes without much forethought, writes Carolyn Bailey, Americas digital tax administration services leader at EY. It sells newspapers, magazines and journals, and it attracts television viewers.

Overall, 2017 saw significant changes in Chinese tax rules and in the broader regulatory environment. Many of the changes reflected the reorientation of government policy towards an evolving cross-border investment landscape. The digitisation of the economy, as well as the tax administration, was also a key driver of developments.

Generally, a gain realised by a non-resident of Canada on the sale of shares of a corporation that derive more than 50% of their value from Canadian real property (CRP), being real properties or resource properties situated in Canada, at any time in the 60 months preceding the sale is subject to tax in Canada. Such shares are known as "taxable Canadian property" (TCP). Exceptions exist for holdings of shares listed on a designated stock exchange where the holder owns less than 25% of any class of shares of the issuer and under the provisions of certain tax treaties. On May 1 2017, the Canada Revenue Agency (CRA) released a Technical Interpretation (TI) (2015-0624511I7) describing the approach that should be followed to make the 50% determination if the property of the corporation (Parentco) includes shares or debt of a wholly-owned subsidiary corporation (Subco). Although the TI addresses a prior version of the TCP definition, the comments appear to be applicable to the current definition, which employs essentially identical language relating to derivation of value.

The concept of corporate legal migration, i.e. the change of domicile of any legal entity, is not included in the Chilean tax law. Thus, its effects depend on the concept of legal residency given by the country from which the company migrates, as well as by the country to which the company moves to.

On June 27 2017, the Prime Minister of Bosnia and Herzegovina adopted a decision ratifying the income tax treaty between Bosnia and Herzegovina and Romania, which was signed on December 6 2016. When it becomes effective (pending Romania's ratification), the treaty will replace the former Yugoslavia–Romania income and capital tax treaty of 1986.

Read this month's special features on Tax technology and transformation and Mexico

India's Supreme Court has reinforced its decision in the Formula One permanent establishment (PE) case and further clarified the application of service and agency PE rules in a recent case.