Number 5 - 2006 contains the following:
 

This article discusses the Code of Conduct on Transfer Pricing Documentation, as adopted by the EU Member States on 20 June 2006. The authors find this Code of Conduct a first step in the right direction to reduce the mentioned complications for MNEs to effectively obtain the intended benefits, but still several outstanding issues first need to be dealt with. Therefore, the authors present a critical analysis of the Code. Next, although the Code has not yet been implemented in the Netherlands, it is important to look at its possible effect there. And finally, now that the Code has been adopted by the EU Member States how far are those States with its implementation?

Here, the authors provide an overview of the transfer pricing documentation rules of Germany and France. These rules are inter alia compared with the EU Joint Transfer Pricing Forum’s master file approach. Both sets of transfer pricing documentation rules, the obligations they involve, timing and penalties are the subject of comparison between the French and German practice. The article ends with a clear summary of the authors' findings and some final remarks.

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 for 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, published in the July/August 2006 issue.