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ARTICLES
International
Transfer Pricing and Value Added Tax in the European Community: Is There Room for Interaction and, If So, Where?
Emanuela Santoro
pp. 147-164
This article analyses whether there is room for interaction between transfer pricing and indirect tax with regard to their respective valuation principles and, if there is room for such interaction, where such interaction can be found and whether it is recommended.
United States
Glaxo Transfer Pricing Case: Economic Rationale, Legal Framework and International Issues
Andrea Musselli and Donatella Marchetti Hunter
pp. 165-173
This article analyses the GlaxoSmithKline case, the largest tax dispute ever litigated in the world, from an economic perspective and discusses the impact of the decision on audits of taxpayers’ transfer pricing policy.
International
Caught between Globalization, the OECD and the European Union: APA Provisions in Italy and Germany
Napoleão Dagnese
pp. 174-177
This article looks into the Italian and German APA provisions under scrutiny by the EU Joint Transfer Pricing Forum, as well as the developing best practices.
RECENT DEVELOPMENTS
Belgium
New Transfer Pricing Practice Note Leaves Taxpayers between Hope for Heaven and Fear of Hell
Isabel Verlinden and Rob Peeters
pp. 178-180
The Belgian tax authorities have issued a practice note on transfer pricing documentation, which provides additional guidance for situations where information requests are issued by the tax authorities.
Estonia
Changes to Transfer Pricing Legislation
Kaspar Lind and Marek Herm
pp. 181-184
Transfer pricing rules have made a comeback of sorts in Estonia; although the rules were introduced six years ago, in practice they were not applied.
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Hungary
Advance Pricing Agreements: The Way Forward?
Zaid S. Sethi
pp. 185-188
The introduction of new legislation providing for APAs in Hungary represents a significant step by the government to standardize the approach to pricing future transactions.
India
Constitutionality of Reference by Assessing Officer to Transfer Pricing Officer: The Sony India Case
P. Raj Kumar Jhabakh and Saurabh Tiwari
pp. 189-191
This article analyses the relevant Income Tax Act provisions and the issues considered in the case Sony India (P.) Ltd.
Italy
Supreme Court Decision on Transfer Pricing: Burden of Proof, Anti-Avoidance Interpretation and Abuse of Law Principle
Giovanna Chiesa and Giammarco Cottani
pp. 192-197
The Italian Supreme Court recently issued its ruling in a case concerning the arm's length value of transactions between companies belonging to an international group.
Netherlands
The Patents Box: Approved and Implemented in the Netherlands
Eduard Sporken and Edwin Gommers
pp. 198-203
This article considers the potential implications that the Patents Box will have on the economy, as well as the criteria for applying the Patents Box itself and related considerations.
Norway
Proposed Transfer Pricing Reporting and Documentation Requirements
Marius Leivestad and Geir F. Furøy
pp. 204-210
The Norwegian Ministry of Finance has released a white paper on reporting and documentation requirements for taxpayers with controlled domestic and cross-border transactions.
United States
Update on Sec. 482 Services Temporary Regulations
Steve Allen, Rahul Tomar and Deloris R. Wright
pp. 211-216
In 2006, the US Treasury Department issued temporary regulations regarding the provision of intercompany services, and subsequently solicited and received numerous comments on their content and implementation.
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