Number 2 - 2006 contains the following:
 

A detailed discussion on the application of transfer pricing rules in e-commerce taxation including on income characterization and attribution.

The author looks at the effectiveness of tax administrations, with regard to accountability and fairness, and uses the findings to evaluate the performance of the Thai Revenue Department.

The Full Federal Court’s decision, dismissing the taxpayer’s appeal, on the deductibility of interest on stapled securities and application of anti-avoidance provisions is briefly discussed.

Australia, in order to encourage the growth of the venture capital industry, amended its tax legislation in 2002 and 2004, and introduced a number of tax concessions for the industry. The author examines the impact of these changes, with regard to venture capital limited partnerships.

India introduced transfer pricing regulations in 2001 and the first round of transfer pricing audits were completed in 2005. The author provides a critical analysis of the regulations including the use of data for comparability analysis, the use of secret comparables, the confidentiality of information, etc.

With the continuing growth of the Indian economy, an increasing number of foreign companies are establishing operations and posting expatriate personnel in the country. The authors provide a comprehensive overview and discussion of the myriad of tax and regulatory issues that an expatriate would face in India.

A succinct discussion on the “rental tax” that is imposed by Kazakhstan on the export of crude oil and natural gas.

The author provides an overview of the tax regime affecting non-resident individuals in Sri Lanka.