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ARTICLES
International
Outline for a Possible Home State Taxation Pilot Project for SMEs
Rolf Diemer and Matthias Mors
111-116
The authors present the basic approach and procedures, and go on to describe which enterprises qualify, how the home state and the home state group are determined, and the coverage of both taxes and sectors.
Commission Proposal for Home State Taxation
Otmar Thömmes, Stephan Rasch and Tanja Koch
117-123
Here, the authors present their own analysis of the Commission’s Home State Taxation Proposal. Some unexpected effects are described, e.g. like distortion of competition (between participating and non-participating SMEs), and tax planning opportunities within groups.
India
An Integrated Approach to Formulating a Transfer Pricing Strategy Concerning Marketing and Distribution Affiliates
Narayan Mehta
124-143
This article presents a comprehensive analysis of the possible and proper transfer pricing policy for MNEs operating in India through either a trader/distributor, limited distributor or an agent/service provider.
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RECENT DEVELOPMENTS
France
Form to Request a Private Ruling on the Presence of a Permanent Establishment
Pierre-Jean Douvier
144-150
Greece
Pre-Approval Procedure for Royalties and Management Fees
Dr George S. Mavraganis
150-153
Peru
New Transfer Pricing Regulations
154-157
United States
An Assessment of APA Fee Increases
Joy Dasgupta, Jason Porta and Deloris R. Wright
158-161
DOCUMENTATION
Denmark
New Transfer Pricing Documentation Regulation
Arne Møllin Ottosen and Michael Nørremark
162-165
Denmark
Statutory Order on the Documentation of Pricing of Controlled Transactions
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