|
ARTICLES
International
Pan-European Comparables Searches – Analysing the Search Criteria
Jaap Reyneveld, Edwin Gommers and Henrik Lund
79-88
This article discusses the current status of attempts to achieve harmonization of comparables search requirements, mainly from a pan-European perspective. A general background on comparability analysis is provided. Finally, a number of technical issues involving pan-European comparables searches is addressed.
International
Transfer Pricing Comparability: Perspectives of OECD, Australia and United States
Anton Joseph
89-99
This article looks into recent OECD developments regarding the role of comparability, along with the position of Australia. It concludes with a discussion on new service regulations issued in the United States that could bring some certainty to transfer pricing in relation with services.
RECENT DEVELOPMENTS
Brazil
Application of Arm's Length Principle to Intangibles
100-105
This article clarifies Brazilian transfer pricing rules and the application thereof to transactions involving intangible assets. Special consideration is given to different approaches adopted by the OECD and other countries around the world.
Ecuador
Transfer Pricing System: Current State and Future Prospects
Enrique Díaz Tong and Rodrigo Garcés Velalcázar
106-108
A discussion of key aspects of the Ecuadorean transfer pricing rules and anticipated future amendments thereto. Topics addressed include taxpayer obligations, determination of related parties, adoption of OECD methods and penalties.
|
Germany
Same Procedure as Last Year? Competent Authority Procedures and Advance Pricing Agreements Revisited
Stephan Schnorberger
109-115
New circulars were issued in 2006 with regard to competent authority procedures and advance pricing agreements. This article provides a practical and legal overview of the structure and process of competent authority procedures and APAs, and considers the pros and cons.
Poland
Initial Experience with APA Practice and Update on Recent Changes to APA Procedures
Sylwia Rzymkowska
116-118
A type of advance pricing agreement recently became possible in Poland. This article describes the application procedure and presents a brief overview of experience to date together with a summary of 2006 statistics.
Portugal
Thin Capitalization Rules
Francisco de Sousa da Câmara and José Almeida Fernandes
119-123
This article describes the Portuguese thin capitalization rules, their development over time and how they relate to EC Treaty law.
DOCUMENTATION
Canada
Comparison of Analysis for Income Tax Transfer Pricing and Customs Duties: New Information Circular
J. Scott Wilkie
124-128
A discussion of Circular IC06-1, issued 5 October 2006 by the Canada Revenue Agency. Useful with regard to the transactional analysis for customs duty purposes, the Circular can also help taxpayers understand the transfer pricing methodologies applied by the CRA .
Canada
Income Tax Information Circular IC06-1 – Income Tax Transfer Pricing and Customs Valuation
129-142
Forward the ITPJ Preview
to a colleague
|