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ARTICLES
International
Transfer Pricing Risk Management
Danny Oosterhoff
46-43
Oosterhoff presents one of the first comprehensive and structural analyses of the issues involved. After discussing an example of a transfer pricing risk framework, he concludes with setting forth some of the critical elements of a succesful transfer pricing risk management strategy.
Attribution of Profits to Permanent Establishments of Banks
Silvia Mascarello
54-73
The author undertakes a critical and thorough analysis of the OECD Dicussion Draft in general and, more specifically, of the the application of the Discussion Draft to the banking sector. The main issue in this is the attribution of free capital to permanent establishments of banks. This practice-oriented article contains useful links between the Discussion Draft theory and its possible applications.
Netherlands
Attribution of Profit to a Permanent Establishment of a Bank
Anuschka J. Bakker
74-78
This article presents a discussion and analysis of recent Netherlands case law concerning one of the issues dealt with in the previous article by Mascarello. The decision of the Court of Appeal of Amsterdam, the position of the Netherlands tax administration and the final decision of the Supreme Court are scrutinized. The author concludes with summarizing the main consequences of the decision as well as the remaining uncertainties.
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RECENT DEVELOPMENTS
Denmark
Tax Law on Intra-Group and Shareholder Security from a Transfer Pricing Perspective
Jakob Bundgaard
79-89
India
Advance Ruling on Taxability of Fees Paid to Canadian Consultants for Work Done in Canada
Sanjay Sanghvi
89-91
Italy
Provincial Tax Court Decision on Documentation Supporting Cost Sharing Agreements
Nicola Saccardo
91-95
Netherlands
Global Trading
Anuschka J. Bakker
95-100
United States
Proposed Regulatory Guidance Issued for Domestic Production Activities Deduction
Gregory G. Palmer, Michael A. DiFronzo and David S. Lee
100-107
Essential reading
The Attribution of Profits to Permanent Establishments: The taxation of intra-company dealings is essential reading for anyone dealing with PEs in their daily practice, including tax advisers, tax lawyers, tax authorities and accountants.
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