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Bartosz Glowacki Poland wants to introduce controlled foreign corporation (CFC) rules, which may start to apply even already to 2015 profits. The Polish government has cherry-picked from CFC mechanisms around the world, but somehow only the most oppressive ideas were copied. Any company seated in a territory formally blacklisted as a tax haven by Polish Ministry of Finance (or a territory with which there is no exchange of information agreement) will be treated as a CFC. No exemptions are provided. Another CFC category, which includes even companies seated within the EU and tax treaty countries, are non-Polish companies, in which the Polish tax resident (corporate or individual) owns for an uninterrupted period of 30 days per year, directly or indirectly 25% of share capital, voting rights or share in profits, when at least 50% of that company's income is passive and taxed at a rate lower than 14.25%.

In the first decision of its kind, the Tax Court of Canada ruled that while Marzen Artistic Aluminum provided sales and marketing staff to Starline International at arm's-length, the documentation provided was insufficient.

Victor Adegite of KPMG Nigeria looks at the advance pricing agreement (APA) option as a tool taxpayers can use as part of their transfer pricing risk management, highlighting the benefits of different types of APA and looking at how APA programmes operate in other jurisdictions.

Robert Jacobson's practice covers a wide range of tax matters, particularly the effects of federal income tax structuring on partnerships, corporations and individuals in complex domestic and international business transactions. He is an experienced M&A, reorganisations and capital markets tax lawyer, that includes expertise in master limited partnerships.

Andrea Bonzano, head of tax at Fiat, discusses his company’s global transfer pricing strategy, including its preferred methodologies and how it is responding to BEPS discussions.

Andrea Bonzano, head of tax at Fiat, discusses the pros and cons of different transfer pricing methods in an interview with TPWeek, and provides his views on BEPS and US inversions.

Taxpayers can question the US Internal Revenue Service (IRS) about why it has issued a summons if they have reason to believe that bad faith was involved.

Andorra has signed the OECD’s Declaration on Automatic Exchange of Information in Tax Matters.

By Jamal Hejazi, chief economist, Dale Hill, partner and Mark Kirkey, partner, of Gowling Lafleur Henderson – Taxand.

Arun Jaitley, the Indian finance minister, has delegated responsibility for oversight of the Indian tax disputes involving Vodafone because he advised the company on tax issues during his legal career.