ibfd tax haven 3...ibfd tax haven ne 2015 3 lease address all contributions to: editorial team laura...

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IBFD Tax Haven June 2015 3 Please address all contributions to: Editorial team: Laura Roest, Afke Lijzenga and Yvonne Schellart Contact: [email protected] Next Deadline: 24 July 2015 Cooperation between the University of Amsterdam and IBFD On 28 April 2015, the University of Amsterdam (UvA) and IBFD officially signed a broad cooperation agreement, which includes inter alia our new joint Advanced Master’s in Inter- national Tax Law: Principles, Policy and Practice. The agree- ment was signed by Sam van der Feltz (CEO) and Pasquale Pistone (Academic Chairman), on behalf of IBFD, and by Edgar du Perron (Dean of Law) and Marjoleine Zieck (Direc- tor Graduate School of Law), on behalf of the UvA. Besides other authorities and lecturers from the UvA, the ceremony was also attended by Joanna Wheeler (Programme Director) and Carlos Gutiérrez (Principal Research Associate). Our work on the LLM programme continues at full steam. In the week of 24 August the new students will participate in the introductory week organized by the UvA, and they will also be welcomed at IBFD. The Inaugural Lecture, on Friday 28 August, will be given by Professor John Prebble, an interna- tionally respected academic and former IBFD trustee. The regular teaching programme will start on 1 September. For more information about the LLM programme, see our intranet: http://intranet/llm, where you can find inter alia the course programme and lecturing timetable, and a detailed brochure about the programme. For those of you outside the Amsterdam office, please see the UvA Advanced Mas- ter webpage.Carlos Gutiérrez Puente Government Training in the Great Rift Valley On 22 March 2015, we headed to Nakuru, Kenya to pro- vide a week-long training session on international taxation for Kenyan officials from various government institutions involved in one way or another in tax treaty negotiations. The training was a first “follow-up”, in the sense that it followed, in the specific case of Kenya, the 2014 training provided in Amsterdam to officials from 11 African coun- tries, an initiative sponsored by the Dutch government. Nakuru is a busy and vibrant town about a three-hour drive northwest of Nairobi. It is a town of heavy traffic, situated as it is on the main highway used by heavy trucks for transporting goods to Uganda and Sudan, but it is also home to the beautiful Lake Nakuru, one of the Great Rift Valley soda lakes, which is protected as by Lake Nakuru National Park. It was astonishing to realize that just ten minutes by car from our hotel, on the edge of the town, was the entrance to a huge national park with an amazing diversity of wildlife. The location in the town of Nakuru allowed participants to leave aside their regular work to concentrate on the training and, in this setting, the training also served as a team-building exercise among officials from various insti- tutions, and between them and us. Perhaps having Emily as part of the team helped make us closer to the partici- pants. In any case, we very much enjoyed the opportunity to interact informally after the training and to get to know a bit of Kenyan cuisine, culture and hospitality. The training was quite intensive, due to the number of subjects under consideration, their complexity and the short period of time available to cover them. It aimed at providing a better understanding of the significance and impact of domestic law and tax treaties, and a better understanding of the viewpoint of each governmental institution involved (not only the National Treasury and the Kenya Revenue Authority but also non-tax departments like the Ministry of Foreign Affairs and International Trade, the Kenya Investment Authority and the State Law Office). For officials from the Ministry of Foreign Affairs and the Kenya Investment Authority, for example, we concluded

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Page 1: IBFD Tax Haven 3...IBFD Tax Haven ne 2015 3 lease address all contributions to: Editorial team Laura Roest, Afke Lijzenga and Yvonne Schellart • Contact redactieibfdorg • ext Deadline

IBFD Tax HavenJune 2015 3

Please address all contributions to:Editorial team: Laura Roest, Afke Lijzenga and Yvonne Schellart • Contact: [email protected] • Next Deadline: 24 July 2015

Cooperation between the University of Amsterdam and IBFD On 28 April 2015, the University of Amsterdam (UvA) and IBFD officially signed a broad cooperation agreement, which includes inter alia our new joint Advanced Master’s in Inter-national Tax Law: Principles, Policy and Practice. The agree-ment was signed by Sam van der Feltz (CEO) and Pasquale Pistone (Academic Chairman), on behalf of IBFD, and by Edgar du Perron (Dean of Law) and Marjoleine Zieck (Direc-tor Graduate School of Law), on behalf of the UvA. Besides other authorities and lecturers from the UvA, the ceremony was also attended by Joanna Wheeler (Programme Director) and Carlos Gutiérrez (Principal Research Associate).

Our work on the LLM programme continues at full steam. In the week of 24 August the new students will participate in the introductory week organized by the UvA, and they will also be welcomed at IBFD. The Inaugural Lecture, on Friday 28 August, will be given by Professor John Prebble, an interna-tionally respected academic and former IBFD trustee. The regular teaching programme will start on 1 September.

For more information about the LLM programme, see our intranet: http://intranet/llm, where you can find inter alia the course programme and lecturing timetable, and a detailed brochure about the programme. For those of you outside the Amsterdam office, please see the UvA Advanced Mas-ter webpage.■

Carlos Gutiérrez Puente

Government Training in the Great Rift ValleyOn 22 March 2015, we headed to Nakuru, Kenya to pro-vide a week-long training session on international taxation for Kenyan officials from various government institutions involved in one way or another in tax treaty negotiations. The training was a first “follow-up”, in the sense that it followed, in the specific case of Kenya, the 2014 training provided in Amsterdam to officials from 11 African coun-tries, an initiative sponsored by the Dutch government.

Nakuru is a busy and vibrant town about a three-hour drive northwest of Nairobi. It is a town of heavy traffic, situated as it is on the main highway used by heavy trucks for transporting goods to Uganda and Sudan, but it is also home to the beautiful Lake Nakuru, one of the Great Rift Valley soda lakes, which is protected as by Lake Nakuru National Park. It was astonishing to realize that just ten minutes by car from our hotel, on the edge of the town, was the entrance to a huge national park with an amazing diversity of wildlife.

The location in the town of Nakuru allowed participants to leave aside their regular work to concentrate on the training and, in this setting, the training also served as a team-building exercise among officials from various insti-tutions, and between them and us. Perhaps having Emily as part of the team helped make us closer to the partici-pants. In any case, we very much enjoyed the opportunity to interact informally after the training and to get to know a bit of Kenyan cuisine, culture and hospitality.

The training was quite intensive, due to the number of subjects under consideration, their complexity and the short period of time available to cover them. It aimed at providing a better understanding of the significance and impact of domestic law and tax treaties, and a better understanding of the viewpoint of each governmental institution involved (not only the National Treasury and the Kenya Revenue Authority but also non-tax departments like the Ministry of Foreign Affairs and International Trade, the Kenya Investment Authority and the State Law Office). For officials from the Ministry of Foreign Affairs and the Kenya Investment Authority, for example, we concluded

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the course by highlighting the budget impact of tax trea-ties and the risk of treaty abuse, together with the political problem of renegotiating or terminating them. Another theme was the necessity of thoroughly preparing for and coordinating tax treaty negotiations and, in view of their impact on domestic law, avoiding rushing into tax treaties.

We very much appreciated the level of interest shown by participants, especially considering the length of the days and the intricacy of some matters. The training was highly interactive, and we did our best to answer all questions – both basic inquiries and more specific questions put forward by advanced students – so as to satisfy the par-ticipants’ needs based on their level of expertise. To give one example, we spent time clarifying specific actions of the BEPS initiative, while at the same time dealing with questions related to policy and even the administrative implementation of treaties.

The participants identified several areas where a follow-up would be considered useful. These were included in the final evaluation. It would be great if IBFD would be able to further support the Kenyan authorities in these areas.

On the way back to Nairobi, we had the chance to visit Lake Naivasha, another nature sanctuary, which is home to over 400 different species of birds and a large pop-ulation of hippos, which graze along the lake’s shores every night. Despite the risk, Jan still managed to take his regular evening walk.

Overall, it was a great pleasure, an honour and a very rewarding experience to conduct this training for the Ken-yan government and to experience something of what the country has to offer.■

Carlos Gutiérrez Puente, Emily Muyaa and Jan de Goede

Time to Say Goodbye

In the sixties, I travelled to the Balearic Islands and Tunisia. Those were my first international trips. After being enlisted in the army and receiving the usual training, I had to make a choice: stay in the Netherlands or serve my duty in Surina-me. As I am a lover of warm weather, it was not difficult to decide. I left for Suriname in 1971 (it took about 11 days on a small ship) and I had my first tropical experi-ence, which changed and broadened my view. During that time, I was able to go to Brazil for a month, where I walked along the famous beaches in Rio. After 16 months in Suriname, there was no boat, so we flew by plane via Madrid to Amsterdam.

Little did I know that in 1971 my future wife would come from Indonesia to train as a nurse in the Netherlands. After several different jobs, I also applied to learn everything about nursing. There I met Ilse and we married in Decem-ber 1974. The next year was my first visit to Indonesia, where I discovered that I had a huge family. After Suriname, it was not difficult to adjust. It felt like my second home and I managed to pick up the “Bahasa Indonesia” after a while.

We travelled a lot and made our first non-tropical trip to the former Yugoslavia, Bulgaria, Turkey and Greece. A visit to Singapore, Hong Kong and Japan was next on the list.

As a self-taught artist, my first exhibition took place in 1980 in Enkhuizen showing drawings, watercolours, etchings and some oil paintings. Subsequent exhibitions followed in Hoorn and Den Haag. It was a very productive period.

After almost 15 years working in hospitals and homes for the elderly, I decided to look for another job. I first worked for IBFD via an agency. Much to my surprise, when I first arrived at the Plantage Westermanlaan (close to the Zoo), I was welcomed by Freek, who happened to be my wed-ding photographer back in 1974. I thought that it was the wrong address and asked him what he was doing there. He replied, “What are you doing here?”

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My first task at IBFD involved tagging all the publications available at that time. Due to the cold, I was always very happy when Mr van Hameren came with hot soup from “de Poort”.

After a visit to London, I officially joined IBFD on 19 De-cember 1990.

During my time here, I have seen many developments, including the first CD with tax treaties that saw the light of day. Later, I had the chance to join Rijkele for the CD test-ing in Limburg. After a while, I went on my own to Limburg (spending almost the whole day in the train). At that time, Wim Wijnen was my manager. During my first years at IBFD, I also learned a lot from Gerard and Riina.

Meanwhile, my job within IBFD was made clearer, and when Stan Meyer became my manager, the name “EPD” popped up.

I remember that sometimes after heavy rainfall, the base-ment of the “ONK” building would flood and the carpet would be soaked, which made a funny sound underfoot. I started to remove the smelly carpet. The thick walls were finally injected with a purple substance, which did the trick and stopped the flooding. Eventually, the office became too small for all of the staff members, and later we moved to the Wenckebachweg. During the holidays, I continued to travel internationally, visiting the United States and China.

The story is not complete without mentioning this. In Octo-ber 2007, after a great and passionate marriage between two soulmates (33 years), Ilse passed away suddenly. IBFD in general, Stan, Laura and my direct colleagues as well as many other people proved to be of great support during this difficult period. Thanks to you all, I was able to continue.

In 2011, something happened that had a great and pos-itive impact. As part of an IBFD exchange programme, I worked for three months in the KL office, visiting Indonesia a couple of times during weekends. Bindo always ad-vised, “Just say that you are visiting friends when entering Malaysia”. I finally received the work permit just a short time before leaving Malaysia. Enriched with memories of this time and becoming a close friend of a Malaysian fami-ly, I returned to the Netherlands.

What also helped a lot during this time was the painting project with Efin in the previous office at the Wenckebach-weg. We had to paint the workspace with designs that represented the international feel of IBFD. It was a great experience.

After such a long time (almost 25 years), many changes and meeting many lovely people from all over the world, I have now decided to take early retirement and will there-fore leave the company as per 1 July 2015.

As many of you know, I will spend more time in Asia and will explore other activities in the region. In practice, this will mean having my base camp in Indonesia and, if possible, also a pied-à-terre in Malaysia. Maybe I can start painting again and obtain more knowledge about plants that can be used medicinally to help people. If I am bless-ed with the same genes as my mother (who is now 92!), there will be enough time to meet and help people.

You can be sure that I will remember each and every one of you, no matter where I am on this globe.

Bless you all. Stay in good health!■

Love and a big hug,Rob van der Ploeg

Hellos and GoodbyesJoiners Guido Verheul Course Coordinator, ITA Monique Visser Sr Marketing Coordinator, Marketing Team Aart Verdonk Tax News Service Editor, CAT Eóin Winfield Staff Member, EPD

Leavers Shima Heydari Senior Research Associate, VAT Team Casey Kendel Account Manager, US Sales Team Frank Webb Regional Account Manager, US Sales Team Mike Phillips Project Coodinator, IT Support Bob Michel Research Fellow, GTTC Neil Roberts Staff member, Finance

Jan de Goede has been appointed Visiting Professor for International Tax Law at the School of Finance of Renmin University, China. The official ceremony of the appointment led by Prof. Qingwang Guo, Dean of the School of Finance, was held at a conference also attended by several tax professors, by Mr. Tizhong Liao, Director General of the International Taxation Department of the Chinese SAT, and by many students.■

Congratulations ...

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Awarding scientific excellence in the name of Frans Vanistendael… the shortlist is already available!The scientific achievements of Frans Vanistendael have certainly made their mark on European and international tax law. Frans is currently in one of the most productive scientific periods of his life, enjoying research, writing and teaching to a great extent. He is a very rigorous and innovative thinker and IBFD was fortunate to have him with us for seven years.

Promoting excellence through an award bearing his name has important symbolic value for IBFD. It reflects our mis-sion of fostering the dissemination of international tax law and acknowledges pure technical merit in research and groundbreaking scientific written achievements.

The “IBFD Frans Vanistendael Award for International Tax Law” is not just one more award in the tax community. Its aim is to be the leading award, an “Oscar” of taxation, (or, maybe one day we’ll know this award as “the Vanisten-dael”). Any ideas for a nickname? Its concept is simple: all publications (articles, books and book chapters) on Euro-pean and international tax law written in the previous year are eligible, no matter what age the authors are, where they come from or which publisher they have. Yes, IBFD staff are also welcome to apply or nominate publications for next year’s edition!

This year we received applications from authors, from members of the jury, but also from readers who believed in the groundbreaking nature of publications. Nine of them have been shortlisted by the jury and are now available on the dedicated prize website. This year’s winner will be announced on 7 September 2015 during the GTTC Duets Seminar at our Amsterdam office.

The jury is currently in the process of assessing the short-listed publications on a comparative basis.

Who will win? Wait and see... Or perhaps not! Why don’t you rank them yourself and choose your favourite one (as you probably do with the Oscars)? Access the list avail-able on our website and grant yourself the pleasure of some good reading (in case you haven’t read them yet). I personally like all of them! A suggestion for the readers of Tax Haven for the upcoming sunny days!■

Pasquale Pistone, Academic Chairman

Cross Border CookingSPICY PRAWNS

I love cooking, and I love cookbooks. One of my favourite cookbook writers is Sylvia Witteman. The stories introducing her recipes are long and witty; her recipes are short and tasty. This recipe for “Pi-kante garnalen, voor twee personen” is entitled “Ver-liefd” (In love), and it tells the story of how she was wooed by the man she fell in love with and eventually married. He invited her for dinner.

The first course was avocado with shrimps and mayon-naise. The second course: large steaks in a bacon and cream sauce. For dessert: a huge trough of homemade tiramisu. She ate it all, and lots of it, because she was in love with him. It was an act of love – but the only one that evening, because, although she ended up in his bed, it was with a tub next to it. Her enamoured stomach, which could barely cope with the butterflies, couldn’t handle all that richness. She concludes with the following admo-nition: “Let this be a lesson to you, dear singles! Don’t smother the passion in bacon and cream. Keep the food light and elegant. Spicy prawns, for instance. Very easy, very quick, and they make an overwhelming impression”.

For two: ► 500g raw unshelled prawns (or more when frozen; let

them defrost beforehand) (I buy easy-peel wild “gam-ba’s” at the Albert Cuyp market in Amsterdam)

► 1/2-1 fresh red chilli, according to size and taste (de-seeded and chopped; I sometimes use a tablespoon of sambal oelek instead)

► 3-5 cloves of garlic, according to size and taste (chopped)

► bunch of flat-leaf parsley (chopped) ► dash of olive oil ► splash of white wine (or dry sherry, or dry vermouth) ► baguette ► 1 lemon

Pour the olive oil into a wide frying pan.Add the chilli and garlic. Fry, on a low to moderate heat, for two minutes, stirring all the time.Turn the heat to high, add the prawns and stir-fry them for about two minutes, till they are pink and just cooked.Pour in the white wine and let it bubble up for half a min-

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ute. No longer, otherwise they will get tough.Add the chopped parsley, give it a good stir and serve immediately, in the frying pan, with chunks of baguette and a slice of lemon.

At the table, peel the prawns, one at a time, and dip them in the sauce in the pan (provide water bowls with warm water and lemon. And napkins).Drink cold fino sherry with it (or white wine, a light red wine, or whatever you like).

Sylvia recommends a simple green salad and a nice piece of ripe brie afterwards. A little bunch of grapes, a few wal-nuts. More bread. Full-bodied red wine or port. Finally, coffee with delicious chocolates and an interesting eau de vie.■

Enjoy.

Josepha Olsthoorn, Library and Information Centre

Praat Nederlands met meI have always been a fascinated by learning languages, particularly French. At university, I studied French and later, having lived in France for a number of years, made my love of the language my profession by training as a translator. Then I met a Dutch man and suddenly found myself in the Netherlands. I had never been to the Netherlands before, and had some preconceived ideas about Amster-dam based solely on the stereotypical British tourist (need I say any more?). Suddenly, I had to reorientate myself, alter my ideas both in terms of my professional career as a linguist and my personal life: if I was really going to call the Netherlands home, I would have to do something about learning this new, strange-sounding language, the words of which I could barely distinguish one from another when I first arrived.

It has to be said that it took me a while to get to this point, a point at which I feel ready to take on this rather complex language. Joining IBFD and becoming a member of a team that largely communicates in Dutch has given me exactly that nudge in the right direction I so badly need-ed to get started. Since joining PCD in September of last year, I have taken two semi-intensive Dutch courses at the

University of Amsterdam. Much to my surprise after the initial assessment of my level, I wasn’t put into the “Abso-lute Beginners” group, but was given “Beginner” status. Having never so much as opened a Dutch-language text-book, a few years of passively soaking up the language by listening to my partner on the phone, being immersed in the language at family gatherings and at parties with friends, a little bit seems to have actually sunk in. This did have the drawback, however, that my lessons didn’t start at the “very beginning”, so to speak. Forget the present tense and regular verb constructions; I was thrown in at the deep end with the imperfect tense and a long list of irregular verbs to be learnt by heart.

My main motivation for learning Dutch is not necessarily “integration” in the broad sense of the word. The Nether-lands is (thankfully) a country in which one can quite hap-pily live blissfully unaware that the Dutch language even exists, something that is both a blessing and a curse for non-Dutch speakers. This is in contrast to my experience living in France where it was absolutely essential to be able to get by in French. This was a huge motivational fac-tor during my time there, and allowed me to truly immerse myself in the language and culture of the country, which in turn sped up the language-learning process. As we all know, the Dutch don’t make it easy for us foreigners; you all speak such wonderful English! Even my 67-year old, Frisian native-speaking mother-in-law can express com-plex thoughts in English. It is indeed easy and convenient for non-Dutch speakers to postpone tackling this difficult language. I am guilty of it myself. Why would I put myself through the turmoil of language learning in such a cosmo-politan city and English-proficient country?

My personal reasons for doing so are twofold. With a Dutch partner, and therefore a Dutch social and family circle, one of my goals is to just understand what’s going on around me, to stop being the mute at family gatherings or the person who doesn’t laugh at the joke when in a social situation. For me, this is an important and motivating factor. Secondly, my partner’s sister now has two beau-tiful children who both think that tante Jo has something wrong with her. I try my best to say a few words to them in Dutch. Unfortunately, at 2 and a half and 4 and a half, they don’t yet understand the concept of foreign languages and are increasingly puzzled by the fact that I can’t really communicate with them. This has, of course, led to a few difficult situations when I’ve been asked to babysit… On the flip side, I have found that children are amongst the best people to learn a language with, as they are com-pletely forgiving of your mistakes and entirely innocent in their corrections. Deciding to learn Dutch is therefore something very personal for me and largely based on ac-ceptance and social integration, although speaking Dutch certainly wouldn’t do any harm in my professional life.

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One of the most challenging elements to learning Dutch (or any language for that matter) is maintaining a constant level of motivation. During my courses, I found a new confidence in my (almost previously non-existent) ability. A great deal of time during my twice-weekly, three-hour class was dedicated to role playing. I was highly disap-pointed when I realised that this would be a key teaching strategy, and memories of being 13, sitting in my stuffy French classroom asking my disinterested neighbour, “Où est la Poste?” came flooding back. I must say, though, that as an adult this has proved to be an excellent way to lose my inhibitions and to really throw myself head first into practicing the language.

Before the courses, I had barely uttered a word in Dutch, except for when I was absolutely forced to do so. I was, to say the very least, rather inhibited. What helped greatly in finally attempting to speak in Dutch was that my class-room peers were all as bad as I was; this was a very safe environment in which to get completely tongue-tied. And it was certainly reassuring to see that I was by no means the weakest in the class. Having lived in the Netherlands since 2010, I’d started to feel rather ashamed at my lack of ability to even understand a little of what was going on around me. A common joke and favourite question amongst friends and family had become, “How’s the Dutch coming along, Jo?” Albeit said with good intentions most of the time, there’s nothing worse for confidence than your own ability (or lack thereof) being a source of amusement for others.

The two courses I have followed have been nothing but positive and confidence boosting. Their intensive nature has given real results in a very short space of time, and I have seen my Dutch comprehension skills increase dra-matically. I occasionally try out my still somewhat primitive speaking skills on my colleagues here in PCD who, I have to say, are all fully on board with my Dutch-language learning and have been nothing but encouraging and sup-portive; they have shown a great deal of patience!

Since the course and my good intentions of weekly self-study, I have inevitably become a little lax and not found enough time to continue at the same pace. Lan-guage learning, as most of you already know, requires persistence, perseverance and discipline, especially in a country like the Netherlands where it is all too easy to resort to English. Speaking a language is of course about communication and when communicating in English (my native tongue) is just simpler for everyone concerned, it is all too easy to resort to that. So please, speak to me in Dutch. You might get a slightly odd reply, but I’ll certainly keep trying!■

Jo Hamilton, PCD

Celebration of the Senses

Chado

Last month, IBFD was visited by a very spe-cial guest: Tea Master Herman Soshu Som-sen. Having studied tea for three years in Kyoto, who better to prepare a cup of Matcha green tea for us lucky ones?

Dressed in a black kimono, Mr Somsen explained the key

principles of Chado, a Japanese tea ceremony: harmony, respect, purity and tranquillity. Influences from various religions, such as Christianity, Buddhism and Shinto, can be found in the ceremony.

Traditionally, when attending a tea ceremony in Japan, entrance is through a small “crawling-in” door to create a sense of equality and humility among the attendees. A ceremony can last a good four hours. Luckily, there is no need for starvation: a meal including fresh fish, miso soup and vegetables is served.

When the actual tea drinking starts, the first person to drink the tea apologizes for being the one to drink first, holds the tea cup up in admiration and takes three little sips before passing it on to the next person, who then in turn repeats the ritual.

Back in Amsterdam, Mr Somsen prepared Matcha for us using a tea whisk, tea bowl, iron pot and ladle. Katja was the lucky one to be the first to taste the tea, and she kindly shared the cup with us all. I was surprised to see a bright green, thick substance, which was quite bitter but nicely balanced by the tasty Japanese confectioneries that were also served. After this experience, drinking regular tea seems rather dull!

Annette van Tits, PCD

Taiko

Meanwhile, not too far from IBFD, a Japanese drumming workshop (Taiko) was taking place in a bunker-looking sound studio. Each of us was assigned one Taiko. We start-ed the session by being asked to hit the Taiko as hard as we could, so we could see that however hard we hit it, we could not break it. I found it absolutely fascinating that you

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could go full power on the drum without holding anything back. As a violin player, this was completely new to me!

Banging on it really hard not only created a powerful, vibrant sound, but also produced some sort of synergistic effect in the room. I gave it all I had and enjoyed every minute of it. I didn’t even realize I was getting blisters on my hands until it was over.

Our Taiko teacher explained that Taikos were originally used to communicate with spirits. I could see how these drums could be used for this purpose; there was an amaz-ing energy flowing around us, part of which I happily took home with me.■

Berenice Herisson, Marketing Department

A Year in AmsterdamSpring 2015 saw the arrival of Luna Bai and Yan Zhuang at IBFD. They are the first two participants in a cooper-ation programme on tax research and training between China’s State Administration of Taxation (SAT) and IBFD. Before joining SAT, they studied at the Central University of Finance and Economics in Beijing. They will stay in Amster-dam for one year, working as part of the Asia-Pacific Team.

“Could you describe, in short, what your job will be?”Luna Bai: “At the moment, Shiqi [Ma] is introducing us to the work of the AP Team. We have already written a few TNS reports. One of the main things for us to work on this year is the China Circular Project, which means we will mostly be involved in translating parts of Chinese tax law, regulations and notifications.”

Yan Zhuang: “As well as for work, we are also here to study. We are going to take courses in international tax law, under the supervision of Shiqi.”

“What are your expectations for this year?”Yan Zhuang: “As for me, I work in the Procurement De-partment of SAT, and I hope to gain more knowledge, general and specific, on international taxation. You learn from work and study, but here we can also learn from dis-cussing tax matters with English-speaking colleagues from countries all over the world; we can learn just by listening to their experiences.”

Luna Bai: “I would like to know more about international tax law. I work in the Large Business Department of SAT and, up to now, we have not had too many tax matters about international taxation (because there is another department that deals with international tax matters). SAT has, however, selected 45 multinational corporations (“very large corporation groups” is more suitable) in China to pilot large-business tax service and management, so our department is inevitably encountering many cross-bor-der tax issues arising in relation to these corporations. IBFD is famous for its resources and research in the realm of international taxation and I am very honoured to come here and have an opportunity to study international taxation through the wonderful library, the extraordinary colleagues and my work here.”

“It is a long flight from China to Holland. Is it possible for you to see your family and friends this year?”Luna Bai: “My family will come to visit me here in Holland and maybe we can travel around in Europe during my holidays. But we also plan to go to many of the museums in Amsterdam. I have already been to the Van Gogh and the Rijksmuseum. It is very exciting to see a lot of precious artwork, especially the beautiful paintings that depict the country’s history. The tradition of Western painting is very different from the tradition of Chinese art and it is very interesting to compare them.”

Yan Zhuang: “My husband is coming over in a few weeks; he will stay for quite some time. When he is here, we are going to visit the rest of Holland, see something more of Amsterdam and something of the other places. In my holidays, I also plan to travel in Europe. Germany, France, Italy... I am curious to see all of these different countries and experience a bit of their different cultures.

“Do you prefer to cook or to eat?”Yan Zhuang: “To eat. I am especially fond of the food of the Sichuan region, which is very hot and spicy. I believe Sich-uan pepper is known in Europe as well? But I like cooking too, I often prepare meals together with my husband.”

Luna Bai: “Half-half. I like to go out for dinner with my husband and friends; there is a lot of tasty food to choose from in Beijing. And I like to cook at home, although my cooking skills are somewhat limited: I am good with vege-tables but not that good with meat. So cooking meat is the task of my husband.”

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“Could you tell something about the languages of and character writing in China?”Yan Zhuang: “In Beijing, we speak Mandarin, which is the most widely spoken language in China. But in our home town, we all speak a local language. There are many local languages in China: each province has a different one. They can be very different; sometimes people from one province cannot understand people from another prov-ince. But all of these different languages use the same characters in writing.”

Luna Bai: “We start learning characters when very young, at nursery school, and it continues throughout primary school, so that we know the meaning and notation of the main characters. There are about 2500 characters that we use most, and in combination with each other these characters can form thousands of words and phrases. But there are always characters that remain uncommon. For example, in literature, there are some ancient articles written in characters that not many people still know.”

“What do you like to do when you are not working?”Luna Bai: “I like reading, in particular detective fiction. I am also very fond of watching films. And with my friends I often go out to do karaoke. My favourite singer for karaoke? Faye Wong (王菲), and a band named Mayday (五月天); they are very popular in mainland China, Hong Kong and Taiwan.”

Yan Zhuang: “I like going around and travelling together with my husband. We have been to a number of cities in China, like Hangzhou and Xi’an, some of the ancient capi-tals, but we have also travelled abroad.”

“If you could make something from China well known in the rest of the world, what would it be?”Yan Zhuang: “Maybe some of the Chinese dishes? The Chinese kitchen is very varied and rich in flavours. Kung Pao chicken or hotpot can make anybody happy.”

Luna Bai: “I think Chinese traditional painting. It has less of a history of realism compared to art in the West; Chinese traditional painting is more conceptual and full of poetry, it echoes the Chinese ancient poems and essays. My moth-er is learning to paint now that she is retired; she is very enthusiastic and often shows me photographs of her work. She also hopes that I will learn this traditional art one day.”

Luna BaiYan Zhuang

“How do you see the future?”Yan Zhuang: “I hope to be a happy person and to keep on developing myself, both in work and in life.”

Luna Bai: “I like my job at SAT. I would like to continue with my work there and I hope to become professional in my specialization. I also hope to have a happy life which is rich in experiences, and to keep up an optimistic attitude throughout.”■

Hello everyone! I’m Janice Loke, and I joined the Asia Pacific team based in the Kuala Lumpur office as a Research Associate in November last year. I started my tax career focusing on Malaysian tax compliance, and in that capacity I did tax advisory work for two and a half years. After that, I spent another two years as a US tax analyst at a major inter-national oil and gas shared-services company based in Malaysia, working on the US domestic entities’ tax returns (on both the federal and state levels).

At IBFD, I am responsible for monitoring and reporting on tax, investment, company law and social security developments for Malaysia, the Philippines, Cambodia, Laos, Myanmar and the Pacific Islands. Apart from that, I also participate in research projects, providing relevant information requested by clients regarding the countries concerned. Prior to joining IBFD, I knew very little about international tax, although I did have some basic knowl-edge on the CFC rules for US tax purposes gained from my previous employment. But really, this is a whole new journey for me – coming from a mainly tax compliance background and now moving into researching and writing on various countries’ tax law updates.

In my free time, I enjoy catching up on new movies, stage plays and musicals. I’m a huge fan of a few great musical productions such as Wicked, The Phantom of the Opera and The Lion King. Although we do have several good local productions, I’m sad to say that we don’t really get many international shows in Malaysia (at least compared to our neighbour Singapore). Recently, I’ve gotten into a new hobby – learning how to make natural bath and body products such as cold-pressed bar soaps.Well, that’s just a little about me! I really look forward to continuing my journey with IBFD and gaining more knowl-edge about international tax.■

Janice Loke

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IBFD House Style RefresherYou have probably noticed our new flyers, folders, ban-ners and other branded items. We started rolling out a house style refresher last year and I’d like to tell you a little bit more about it.

The update was necessary to align our print style with our online and corporate identity, which we previously updat-ed. Furthermore, the new TRP design was also based on the corporate house style. It therefore became important to close the gap between our visual identity online and in print.

One of the subgoals was to make the different business lines more distinguishable, as clients often had difficul-ty identifying the different services when glancing over various types of brochures and folders. At the same time it was important to maintain the main design elements, such as the main colours and shapes, so that IBFD’s identity would still be recognizable.

The key design element of the new house style is the portal element of the logo. It is derived from the Muiderpoort and therefore reflects our history, but it also reflects IBFD as the gateway to international taxation. You can find this element, and shapes derived from it, at key places in the design.

We maintained IBFD’s main colours (red, blue and yellow, based on ‘De Stijl’ – a famous Dutch artistic movement) which make IBFD so recognizable. But we have also rolled out new colours for the various business lines, which were already introduced on the website.

Another subgoal was to reduce unnecessary text and intro-duce more supporting images as a main design element. The previous design did not warrant it, but now they are featured prominently on our brochure covers, flyers, ban-ners and other items. This makes it more attractive, but also helps us to portray our main concepts to our audience.

We started on the initial designs together with the design agency that had originally designed our house style. It was agreed that they would be responsible for the main design outline, ensuring the original design remained recog-nizable. However, when we had hired our own graphic designer, this person would further expand on these elements and ensure rollout. So when Cobus de Graaf, a talented and experienced graphic designer, joined the Marketing department, we were able to make big steps in further developing the items in-house.

The rollout of the brand refresher is now nearly complet-ed. It has been rolled out step by step and includes items such as brochures, flyers, roll-up banners, posters, course binders, name cards, forms, and letters.

Soon the new PowerPoint template will also be available, and when all the items have been created, the house style manual will be finalized and put on the Intranet. Cobus is now responsible for internal branding under Sorrel Hid-ding and will thus be responsible for further rollout. If you have any questions about the house style you can drop him an email ([email protected]).■

Tom Groen, Marketing Team

Let the Sun Shine – Solar Panels at IBFDLast year, at the All-Staff meeting in July, when staff was asked about their ideas about the social responsibilities of IBFD, it occurred to me that solar panels would be an interesting investment. Not only would such a scheme be smart way to consume a bit less energy, but it would also reduce our carbon footprint, thus supporting the environ-ment in our own small way.

So, I proposed this idea to Sam, who reacted enthusiasti-cally and asked Edwin to collect some cost estimates from solar panel providers in order to kick-start this project. After consulting our landlord, it appeared that we could only use about half the roof’s surface because of existing installa-tions. But, we were given the green light and we placed an order for solar panels with the Zonnefabriek in Amsterdam.

The installation was planned for 10 December but, unfor-tunately, by that time the weather had turned too windy to continue. It was decided to wait until spring.

Another obstacle which almost forced us to cancel the en-tire operation was that the only way to get the panels onto the roof was to hire an expensive crane; the use of this would cost €2,500 per day and would make the project a bit too costly. Fortunately, Edwin uncovered some of our building’s secrets and found a way to get the installation to the roof through the building itself.

And thus, on 22 April 2015, the solar panels were at long last placed on the roof and connected to our electrical installation. They generate approximately 4500 kWh per year, which saves us at least €1,000 each year. It is true that this only constitutes about 1.5% of our yearly power usage, but every step in the right direction counts. As we say in Dutch: “Alle kleine beetjes helpen” (“every little helps”).■

Steef de Rooi, IT Support

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Pay-per-view access to IBFD Journal Articles from the Library CatalogueOn 30 January 2015, a pay-per-view service for single IBFD journal articles was launched. Pay per view is a new payment model, allowing clients and prospects who do not subscribe to one of our journals to buy single IBFD journal articles by credit card. Pay-per-view articles can be accessed via the corporate website and the Tax Re-search Platform, but also via the library catalogue.

The library catalogue not only contains bibliographic re-cords for all books held by the library but also descriptive records of articles in journals from all over the world, both those published by IBFD and those published by other publishers. The library’s information specialists enrich

Symposium on Cross-Border Exchange of InformationOn 5 February 2015, a sym-posium entitled “Information from cross-bor-der”, organized by the Dutch Tax Litigation Discussion Forum and hosted by IBFD, was held at the Tropenmuseum in Amsterdam. At the annual sympo-sia organized by the Forum, parties involved in tax proce-dures, including judges, lawyers, advisors, tax inspectors academics and business advisors, exchange views on a topic which is important in their daily practice.This time, the topic concerned the cross-border exchange of information from the EU, OECD and Dutch perspectives. There was a full house, with about 90 attendees in total.

The symposium was opened by Wim Wijnen. He indicat-ed that domestic and international instruments to obtain information have expanded substantially over the past de-cades. Therefore, questions like how to deal with unlawful-ly obtained evidence and concealed evidence are arising more frequently. May, for example, stolen data be used in a fiscal procedure? Furthermore, , governments and taxpayers are on the edge, and the intriguing question is whether the balance has gone or is still in sight.

Ms Severine Baranger, Tax Policy Analyst for the OECD-hosted Global Forum on Transparency and Ex-change of Information for Tax Purposes, explained the OECD and EU aspects of the topic. She particularly focused on the switch to automatic information exchange and the question of how the Netherlands is perceived by other countries and the OECD. With the exception of a few shortcomings, the answer is generally positive, because the Netherlands meets its obligations.

Lu-Shen Qua, a coordinating and specialist advisor to the Ministry of Finance, gave an overview of the relevant aspects of the Foreign Account Tax Compliance Act (FAT-CA) and the Common Reporting Standard (CRS). From his presentation, it became very clear that tax administra-tions are collecting a lot of information about individuals to combat tax fraud.

Nicoline Bergman, a lawyer at Pels Rijcken & Droogleever Fortuijn, and Ab Scheffer, coordinator of civil law procedures at the tax administration and, in particular, a specialist in

fiscal procedural law, exposed the powers of a tax inspec-tor to obtain relevant information for the collection of taxes beyond tax treaties and international agreements. Over the past decades, this power has grown substantially, and it now includes relevant information about third persons.

Arnoud Booij, lawyer and tax expert at De Bont lawyers, dealt with the most important aspects of legal protection in the case of the cross-border exchange of information. Furthermore, he gave an overview of the consequences of unlawfully obtained evidence. His presentation showed that taxpayers may often be in a difficult position regard-ing proof, particularly as they do not always have insight into how information about them was collected.

Still, Mr Booij noted, as a last resort, the help of the European Court on Human Rights, which acts as a clear safeguard against violations of taxpayer rights, can be invoked. A clear example is the precedent that information which is held unlawful in a criminal procedure cannot be used to impose an administrative penalty.

After five excellent contributions, a lively debate took place with the audience. It appeared that the approach to many issues is still far from crystal clear. A topic which resulted in a lot of discussion, for example, was the use of unlawfully obtained criminal evidence to impose an admin-istrative penalty.

At the end of a very interesting afternoon, the debate continued at a gathering for drinks, after which everybody went home extremely satisfied and with a lot of interesting new information to think about.■

René Offermanns, Europe Team

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these descriptions with abstracts and keywords. (From 2012 onwards, links to the full texts of IBFD journal articles on the Tax Research Platform had already been added.)

When the idea of developing the pay-per-view service was launched, it was decided that adding this option to the article descriptions in the library catalogue would be of added value, as it would provide an additional method for clients or prospects to access the service. It was not deemed practical to add the shopping cart facility to the library catalogue. Instead, the article record in the cata-logue would be linked to the corresponding article on the Journal Articles Abstracts page of the corporate website, where the user could then order the article. To achieve this, links needed to be added to 5388 article records in the catalogue. Fortunately, this did not have to be done manually! In cooperation with IT, a procedure was de-veloped to add the links in batches, which turned out to be successful for 93.5% of the records. In a collective effort of the library staff, links were added manually to the remaining 352 records within a few days after the launch of the pay-per-view service. As part of the procedure, the catalogue records were also enriched with links to the full texts of articles on the Tax Research Platform for the ben-

Title: Surviving VAT and vuvuzelas : lessons from the 2010 FIFA world cupAuthor(s): Botes, M.Citation: In: International VAT monitor. - Amsterdam. - Vol. 21 (2010), no. 5 ; p. 332-333Imprint: 2010Language: EnglishCountry/continent: South AfricaIn continent/region: Africa Abstract: This article discusses the VAT implications of the 2010 World Championship Football in South Africa.Keyword(s): VATElectronic access IBFD: Read the full article on IBFD’s Tax Research Platform (subscribers only) Order Article

My life after IBFD

I left IBFD at the end of 2011, having worked at its HR department since May 2000. I made a conscious decision to quit and I have had no regrets.

The first months of my “early retirement” felt like a vaca-tion. That wonderful feeling of being able to get up calmly in the morning, every day is the weekend!And, besides having regular babysitting days with our grandson, I could now of course be a babysitter more often, also for the granddaughters. Visiting friends, also retired, was now possible during the day, having lunch together or planning activities. And we were in sore need of going to the gym, my husband and I, which we could now do during the day as well.But the days became ever shorter and shorter, and my planner kept on filling up.

After a while we found a balance. Just because you can do everything doesn’t mean you need to. We are still nice-ly “busy”, but that is a good thing.

Of all the plans I had when I quit, only one has not been realized. I meant to deepen my knowledge of the world of investments. Not fanatically, but in a modest way. I have not been able to do this yet. I’ve been told that now is not the ideal time to invest, but honesty compels me to tell you that I was just not able to motivate myself.

efit of IBFD members. Now any user finding IBFD journal articles in the library catalogue will be presented with two options to obtain the full text of the article: either as part of his or her membership or as an individual article using the pay-per-view option.■

Mario Ubink, Library and Information Centre

We do go on holiday often. My husband and I travelled on a tour from Shanghai to Beijing. We saw many of China’s famous classical landmarks, including the Terracotta Army, the Great Wall, Tiananmen Square and the Summer Palace. Gorgeous!

With our group of friends from the sixties we went on a Baltic Sea cruise, from Copenhagen to the State Hermit-age in St. Petersburg via Stockholm and Tallinn. It was both fun and very beautiful. We are now planning a cruise to the Caribbean.

We also rented a sailing yacht with a group of friends and went on an island-hopping holiday in Greece. What an experience!

Every now and then we visit other friends, who have a house in France, or we travel to southern Spain for a bit of extra sun.

And we’ve been playing bridge since a year or two. Fun, not easy, but good exercise for the brain.

I had a great time working at IBFD, but I very much enjoy my life as it is today!■

Wilma Kenter

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