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ARTICLES
International
Pan-European Comparables Searches: Enhancing Comparability Using Diagnostic Ratios
Edwin Gommers, Jaap Reyneveld and Henrik Lund
219-227
This article discusses the use of financial ratios in the context of identifying comparable companies for transfer pricing purposes, with the aim of addressing the issues that require further guidance in developing a harmonized approach to comparables searches from a pan-European perspective.
International
Commission Proposes Guidelines for Advance Pricing Agreements in the European Union
Bruno Gibert and Xavier Daluzeau
228-232
The EC has proposed and the Council of Ministers has adopted guidelines for APAs in the EU. This article discusses the contents of these proposed guidelines and their potential impact on taxpayers.
India
Information Technology Industry and Related Transfer Pricing Issues
Vispi T. Patel and Vishweshwar Mudigonda
233-238
Since the implementation of transfer pricing rules, three audit cycles have been completed in India. An analysis of the impact of aggressive positions taken by the tax authorities, specifically with regard to the information technology industry.
RECENT DEVELOPMENTS
Argentina
Laboratorios Bago Case: The First Transfer Pricing Case in Argentina?
239-242
Discussion of the ruling in the Laboratorios Bago case. Though technically not a transfer pricing case, this is one of the few Argentine decisions regarding the assessment of prices in cross-border transactions.
Belgium
In the Face of Further Scrutiny from the European Commission on Coordination Centres, New, Genuine, Tax-Effective Alternatives Emerge
Koen Cooreman and Yves Voeten
243-245
Faced with continued wrangling over the status of the Belgian coordination centre regime, an alternative has been created for those coordination centres that mainly carry out financing activities, namely the notional interest deduction regime.
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China
Unified Enterprise Income Tax Law and Its Impact on Transfer Pricing
Luis Coronado and Susana Chou
246-248
The recently enacted Unified Enterprise Income Tax Law contains changes in transfer pricing policy. This article analyses these changes and their potential impact on tax planning in China.
India
Offshore Ruling: Analysis of a Recent AAR Judgment on Taxation of Business Process Outsourcing
Aliff Fazelbhoy and Astha Chandra
249-253
This article analyses a landmark decision by the Authority of Advance Ruling (AAR), In Re: Morgan Stanley and Co. Inc., which addresses the taxation of the business process outsourcing (BPO) arm of a foreign entity in India.
United Kingdom
Advance Pricing Agreements and Thin Capitalization
Andrew Casley and Loïc Webb-Martin
254-256
HMRC has announced changes to the clearance process for companies seeking to apply the relevant treaty rate of withholding tax on interest, as well as an extension of the APA programme. A discussion.
United States
Comments on 2006 Annual Report on Advance Pricing Agreement Programme
Steven Allen, Rahul Tomar and Deloris R. Wright
257-260
The IRS has issued its 2006 Annual Report on the APA programme. This article analyses the Report, with a focus on changes over the years and possible future developments in the APA programme.
Uruguay
Introduction of Transfer Pricing Rules Approved by Parliament
261-263
Uruguay has introduced the concepts of permanent establishments and residence, as well as transfer pricing rules. This article considers the impact of this reform on transfer pricing in Uruguay.
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