Number 6 - 2006 contains the following:
 

An analysis of the Temporary Regulations, issued on 31 July 2006 by the US Treasury Department. Topics are the conditions which determine whether there should be a charge for the intercompany provision of services; when the newly introduced services cost method may be used; various transfer pricing methods provided for valuing the transfer of services; and the treatment of intangibles.

The Netherlands has recently introduced a tax compliance process for large corporate taxpayers, which is implemented by concluding “compliance agreements” between the tax authorities and individual taxpayers. This article discusses compliance agreements; their possible impact on transfer pricing documentation; roles and responsibilities of the tax authorities and taxpayers; and transfer pricing aspects.

This article looks into the transfer pricing aspects of intercompany loans. The author first considers the practical applicability of the OECD Guidelines and the relevance of domestic transfer pricing rules. Then he deals with practical difficulties in providing evidence of the arm’s length nature of intercompany loans. Finally, methods to determine arm’s length conditions and potential pitfalls in this process are discussed.

This article deals with the position of head offices within MNE’s, as far as relevant for transfer pricing purposes, mostly regarding business models as they exist in practice. The business models discussed are the service fee model and the entrepreneurial model.

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, published in the International Transfer Pricing Journal of July/August 2006.