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International Transfer Pricing Journal
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Issue No. 3 - 2015 of the International Transfer Pricing Journal is now available online.

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Number 3 - 2015 contains the following:
Investigations by European Commission into Transfer Pricing Underlying Certain Tax Rulings in the European Union
Eduard Sporken and Yves Cattel

The authors analyse the recent investigations commenced by the European Commission regarding the compatibility with State aid rules, of rulings granted by the tax authorities of several EU Member States.

Transfer Pricing in a BEPS Era: Rethinking the Arm’s Length Principle – Part I
Mirjam Koomen

In the first of a two-part article, the author considers the impact of the OECD BEPS initiative on the application of the arm’s length principle. A historical and comparative analysis is presented of the implementation of the arm’s length principle, as well as the boundaries of the principle in practice. Guidance from the OECD and the case law of various jurisdictions are also considered.


Outcome Testing: Why Year-End Adjustments Cannot Be the First Choice to Bring Intercompany Margins to an Arm’s Length Level
Frank Schoeneborn

This article provides insights on year-end adjustments from a practitioner perspective and illustrates why such adjustments cannot be the preferred solution for multinational enterprises.

United States
Allocation of Income and Deductions among Taxpayers under Section 482 of the United States Internal Revenue Code: Alerting the Courts to the Role of Contractual Interpretation Law in the Transfer Pricing Arm’s Length Comparability Analysis
Amir Pichhadze

This article discusses the task of identifying controlled transactions under review by the Commissioner of the Internal Revenue Service. In particular, it aims to alert courts as to the necessary role of contractual interpretation law in determining the true nature of such controlled transactions.

Prioritizing Transfer Pricing Methods: An Indian and Global Perspective
Ajit Kumar Jain

The author analyses the priority given to various transfer pricing methods from an Indian perspective, as well as from the perspective of the OECD and various countries around the world.


Advance Pricing Agreements

Anton Joseph

The author describes the current landscape in Australia, and briefly considers the state of affairs in China and India, as regards advance pricing agreements.

Permanent Establishment Regulations for Banks and Insurers
Ulf Andresen, Manuel Imhof and Yu Tao

This article focuses on the special provisions for banks and insurance companies, in particular the so-called allocation rules of the PE Profit Attribution Regulations.

Impact of New Transfer Pricing Requirements
Marc Rasch and Pawel Wroblewski

This article provides a general overview of recent transfer pricing developments, accompanied by a contextual overview of implications for taxpayers operating in Luxembourg.

Amended Thin Capitalization Rules

Krzysztof Lasiński-Sulecki

Major changes to the corporate income tax law were introduced on 1 January 2015. These changes, which are generally aimed at reducing possibilities of tax avoidance, include thin capitalization rules. The new rules are more complex and restrictive than those that were in force until the end of 2014.

Transfer Pricing Guidance Issued by Ministry of Finance
Svetlana Stroykova

The author discusses the status of letters issued by the Ministry of Finance, as well as the contents of two such letters that provide guidance on transfer pricing issues.

Revised Transfer Pricing Guidelines
Vatika Bhatnagar

The author discusses the highlights of the revised transfer pricing guidelines issued by the Singapore tax authorities in January 2015, and attempts to shed some light on the impact thereof on Singapore taxpayers.

Proposal for Country-by-Country Reporting
Florentino Carreño and Miriam Sánchez-Briñas

After providing an overview of the regulation of transfer pricing in Spain, the authors analyse the proposed Spanish implementation of country-by-country reporting

Adoption of Substantial Amendments to Transfer Pricing Legislation

Joel Lachlan Cooper

Ukraine’s transfer pricing rules have been substantially amended as part of a recent tax reform. This article presents an overview of the legal framework for transfer pricing in Ukraine in light of these changes and provides some insights into expected future developments.