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• Transfer Pricing - The practical operation of Australia's transfer pricing provisions:  Lessons to be learned  - by Neil Wickenden, HLB Mann Judd, Australia

Roche Products Pty Limited v Commissioner of Taxation
The preliminary and final decisions of the Australian Administrative Appeals Tribunal in the case of Roche Products Pty Limited v Commissioner of Taxation represent the first substantive Australian court or tribunal decisions concerning the practical operation of Australia's transfer pricing tax provisions.  Lessons can be taken from these decisions that apply not only to Australia but also to other jurisdictions.

 

• Transfer Pricing: follow-up: documentary obligation - by Louis Bacot, HLB Maupard Fiduciaire, France

Follow-up:  Documentary Obligation

1. Entry Into force: Transfers carried out as of 1 January 2010 by French companies or French permanent establishments of foreign companies.

 

• Royalty rates as a transfer pricing issue - by Wojtek Komer, HLB Sarnowski & Wiśniewski, Poland

Transfer of intangible goods between related parties usually proceeds in three different ways:  contribution to capital, sale or licence.  Probably the most common, yet the most challenging to transfer pricing issue is licensing. 

 

• Substance over form - by Asger Lehmann Høj, Beierholm, Denmark

Transfer pricing has become an increasing issue at the Danish Tax Administration.  Task forces have been established with some success. Danish holding companies have been used within an international group to optimize the flow through of income, i.e. to reduce withholding taxes and income taxes in other jurisdictions than the ultimate beneficiary company.
 

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