July/August 2006  
ITPJ Preview
International Transfer Pricing Journal
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Issue No. 4 (2006) of the
International Transfer Pricing Journal is now available online.
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Number 4 - 2006 contains the following:
 
COMPARATIVE SURVEY: SUPPLY CHAIN MANAGEMENT

This time, the comparative survey examines the commonly implemented supply chain management structures. Two examples of supply chain management structures are presented. The survey's authors look at these examples from the perspective of their own country. Some of the questions discussed are:

  • which kinds of supply chain management models would be advisable considering the corporate tax system of your country?
  • how is the appropriate remuneration method for certain common supply chain models to be determined?
  • would a contract manufacturer or sales office constitute a permanent establishment of the principal in your country, or not?

More information is presented in the

introduction to the survey.

Introduction
Belgium
Supply Chain Management
Isabel Verlinden and Caroline Costermans
172-177
France
Supply Chain Management
Pierre-Jean Douvier
178-182
Netherlands
Business Restructuring and Permanent Establishments
Jeroen Kuppens and Danny Oosterhoff
183-188
Spain
Supply Chain Management
Florentino Carreño and Gonzalo Oliete
189-193
United Kingdom
Supply Chain Models
Andrew Casley, Sarah Pope and Peter Hohtoulas
194-201
United States
Supply Chain Management
Deloris R. Wright
202-207
RECENT DEVELOPMENTS
Russia
Judicial Challenge of Cross-Border Royalty Fee Structure by Tax Authorities
Vladimir A. Gidirim
208-210
Singapore
New Inland Revenu Guidelines on Transfer Pricing
Edmund Leow and Chris Newman
210-215
Vietnam
Arm's Length Principle under New Transfer Pricing Guidelines and the Impact on Multinational Enterprises
Nguyen Tan Phat
215-230
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Other publications and courses available on Transfer Pricing:

Permanent Establishments

[Online]

The Attribution of Profits to Permanent Establishments: The taxation of intra-company dealings

[Book]

International Tax Aspects of Permanent Establishments

[Course]
GLOBAL COVERAGE OF TRANSFER PRICING ISSUES