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COMPARATIVE SURVEY
Introduction
Tax Treatment of R&D Expenses
Eduard Sporken and Edwin Gommers
3
This survey looks into available alternatives for the tax-efficient structuring of research and development activities abroad. The focus is solely on the corporate income tax treatment of R&D expenses. Discussing various countries, this study is particularly intended to give an update of the most recent rules and regulations in this field.
Belgium
Revised by Dirk Van Stappen, Kristel Van Praet and Ellen Vander Elst
4-10
Denmark
Revised by Henrik Lund
11-13
France
Revised by Alan Katiya, Nathalie Cordier-Deltour and Vincent Berger
14-21
Germany
Revised by Alexander Loh and Stefan im Schlaa
22-23
Hungary
Revised by Csaba László, Tamás Mlinárik and Zsófia Pongrácz
24-26
Ireland
Revised by Tom Maguire
27-30
Bodytext
Italy
Revised by Gianni De Robertis and Maria Eugenia Palombo
31-32
Japan
Revised by James Dodds, Miyuki Murata, Yuko Saegusa
33-35
Luxembourg
Revised by Louis Thomas, Elaine Abery and David Eisele
36-38
Netherlands
Revised by Edwin Brassem
39-40
Portugal
Revised by Júlia Filipe and Dora Madureira
41-43
Spain
Revised by Jose Alberto Estrelles Domingo and Pelayo Oraa
44-46
Switzerland
Revised by Andrew Müller and Thomas Linder
47-48
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United Kingdom
Revised by David O’Keeffe
49-51
United States
Christine Kachinsky, Adam Uttley, Troy Rudd and Charles Medallis
52-53
RECENT DEVELOPMENTS
Denmark
Rulings on Deductibility of Acquisition Costs and Management Fees
Arne Møllin Ottosen and Michael Nørremark
55-58
A discussion on the deductibility of acquisition costs and management fees, which is even more important in the case of private equity funds taking over huge listed companies. Regarding acquisition costs, Danish legislation includes a specific provision, the scope of which has been and is still being tested before courts.
India
Ruling that Domestic Subsidiary of US Company Constitutes a Permanent Establishment
Aliff Fazelbhoy and Farah Petiwalla
59-63
This article looks into the recent landmark decision in the Morgan Stanley and Co., US case, as an attempt to ratify the position that the Indian tax authorities have taken thus far, regarding what does and what does not qualify as a permanent establishment in India.
Slovenia
New Transfer Pricing Rules and Documentation Regulations
Katja Erjavsek
64-71
On Slovenia's accession to the European Union, the Slovenian legislator has introduced, inter alia, transfer pricing legislation. Here, the main elements of that legislation and the formal requirements in the area of transfer pricing are described.
Spain
Major Amendments to Transfer Pricing Legislation
Ramón López de Haro and Mario Ortega Calle
72-75
Spanish corporate tax legislation has been amended to take into account the growing delivery of support services and licensing of intangibles by Spanish parent companies for and to their non-resident subsidiaries. This article describes the main elements of the new Article 16 of the Revised Corporate Income Tax Law and its future implementation by regulations.
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