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This free e-mail service informs you about the contents of the forthcoming edition of International Transfer Pricing Journal.

Issue No. 1 - 2016 of the International Transfer Pricing Journal is now available online.

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Number 1 - 2016 contains the following:


Canada and BEPS: A Progress Report
J. Scott Wilkie

The author considers how the OECD’s BEPS project may relate to the Canadian government’s 2015 federal budget. He also looks into Canada’s evolving tax policy in relation to issues commonly associated with BEPS, even in the absence of specific Canadian tax law responses, so far, to BEPS.

Mandatory Automatic Exchange of Information on Tax Rulings: Political Agreement Reached in ECOFIN Council
Dirk Van Stappen, Wolfgang Oepen and Eugena Molla

This article focuses on the proposed EU framework for the mandatory exchange of information on tax rulings, as defined by the ECOFIN Council on 6 October 2015. Given the parallel nature of the transparency element of BEPS Action 5, some comments thereon are also included.

International Tax Disputes: A Ray of Hope from Japanese Experience

Hiroaki Furuya, Tetsuji Ueda, Shuji Fujita and Cym H. Lowell

In light of the increasing prominence of international tax dispute resolution, especially considering the OECD/G20 BEPS Project, the authors discuss positive developments around the world and present some of the Japanese experience on this issue to serve as a guidepost on how to resolve disputes in a world that is rapidly evolving.


Federal Court Hands Down Transfer Pricing Decision in Chevron Australia Case
Michael Butler, Jessica Pengelly and Ria Neilson

The authors review an important recent decision regarding the operation of Australia’s transfer pricing rules in relation to an intra-group credit facility.

Intangibles in a BEPS World and How the Netherlands Is Complying with OECD Rules
Eduard Sporken and Peter Visser

Many countries have already adopted or are poised to adopt changes to their international tax and transfer pricing systems based on the OECD recommendations under the BEPS project, specifically following the issuance of the package of final reports on 5 October 2015. In addition to discussing the changes to come, the authors address ways in which the Netherlands has implemented the OECD’s recommendations with respect to intangibles.

Transfer Pricing Aspects of Cash Pooling Arrangements in Light of the BEPS Action Plan
Vikram Chand

The author discusses the concept, underlying commercial rationale and types of cash pooling arrangements, and then analyses and comments on the transfer pricing aspects thereof. The analysis also takes into consideration the Actions under the OECD/G20 BEPS Project related to transfer pricing. The author discusses the impact of other BEPS-related actions (domestic and treaty law changes) on cash pooling arrangements, and ultimately suggests a way forward.

Provisional Measure Increases Taxation for Companies under the Deemed Profit Regime Regarding Author, Image Right and Similar Income

Daniel Gustavo Peixoto Orsini Marcondes and Elen Peixoto Orsini

Brazil has enacted several Provisional Measures in an attempt to increase taxation for both individuals and companies, including Provisional Measure 690, which has substantially increased, from 1 January 2016, the taxation of author, image, name, voice and similar rights held by Brazilian companies.

New Transfer Pricing Documentation Requirements for Companies: Routes to Simplification?
Martin Lagarden

The author discusses transfer pricing documentation with a view to plans laid out by the current German government in its coalition agreement at the end of 2013, and with a particular focus on the treatment of this issue according to the OECD’s final report on BEPS Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting), published in October 2015.

Transfer Pricing of Accounts Receivables in the Case of an Extended Credit Period: An Indian Perspective
Mansi Agrawal

In this article, the author considers the transfer pricing aspects of imputation of notional interest on late payments from an Indian viewpoint and the conflicting case law regarding this issue. Finally the author suggests strategies for taxpayers to shield themselves from transfer pricing adjustments in respect of their accounts receivable.

Ireland’s New Knowledge Development Box
Shane Hogan and Caroline Austin

In response to the parameters articulated by the OECD under Action 5 of the BEPS project, Ireland will be the first country to introduce an OECD-compliant intellectual property box regime. The authors review the new regime and provide computational examples of how it will apply.

Italian Patent Box Regime: Thinking Outside the Box or Just More Harmful Tax Competition?
Simone Zucchetti and Andrea Pallotta

The authors examine the technical aspects of the new Italian patent box regime introduced in 2015 which provides for a partial exemption of income arising from qualifying intellectual property rights. Topics considered include historical development, current requirements and international aspects of the Italian patent box regime, comparing it to regimes applicable in other countries. This article consists of two parts, the second of which is primarily focused on the valuations techniques relevant to qualifying IP assets and will appear in a future issue of this journal.

Regulatory Documentation and Country-by-Country Reporting Requirements
Danny Oosterhoff

The Senate of the Dutch Parliament on 21 December 2015 has passed the legislative proposals that will implement country-by-country reporting in line with Action 13 of the OECD’s BEPS Project. The author considers the likely impact of the coming changes and the future outlook in the country.

APA Developments

Blaž Pate and Mateja Drobež Tomšič

Advance pricing agreements will be possible in Slovenia from 1 January 2017. Although detailed rules have not yet been issued, the authors review the procedure for obtaining an APA based on currently available guidance.

Transfer Pricing Actions under the OECD BEPS Project: Impact on Turkey and Attitude towards the Project’s Outcomes

Erdal Aydın

The author analyses the impact on the Turkish tax inspection system, tax law and companies, of the transfer pricing Actions under the OECD BEPS Project; and investigates the attitude of Turkish senior officials, tax inspectors and company executives towards the BEPS Project and its transfer pricing Actions. This article is based on a survey that was conducted by the author.

Black-Listed Jurisdictions as Anti-Avoidance Tool for Transfer Pricing Purposes
Vladimir Didenko

With effect from 1 January 2013, reformed transfer pricing rules have introduced an anti-avoidance tool aimed at transactions between local companies and unrelated counterparties located in so-called black-listed jurisdictions.