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Rakesh Nangia of Nangia & Co look at value shifting in the context of the Shell India controversy.

Andy Baik Andy Baik has joined PwC US as a principal in its International Tax Services practice. Baik possesses experience working in the context of both US and Asian tax systems, and will lead PwC's Sovereign Wealth Fund Tax group initiative in Asia Pacific, as well as taking the lead Asia Pacific regional tax role serving US multinationals.

The court said that companies leaving Spain must have more flexibility on when they pay exit tax The European Court of Justice's (ECJ) decision that Spanish companies transferring assets to another EU member state can defer exit tax payment was unsurprising given the court's rulings in National Grid Indus and Portugal v Commission. But advisers say the ECJ is leaving important questions unanswered.

The economic downturn combined with pressure to tackle tax evasion and aggressive avoidance has intensified discussions of greater tax policy coordination within the EU. Emma Powell looks at how achievable EU tax harmonisation is and in what way it could impact businesses.

Vladimir Kotenko

Sean Foley

Jelena Zivkovic Production of antivirus software systems and other services related to software products are defined as special way of providing intellectual services in areas of complex science projects, especially programming, projecting and realisation. The Montenegrin VAT Law prescribes for the purchase of antivirus system software and other products related to software products that are produced in a foreign country for a Montenegrin company being subject to VAT at the rate of 17% in Montenegro (country of origin of customer). The tax base is the purchase price.

Juan Jose Terraza and Victor Bartels of Ernst & Young explain how two Spanish decisions should focus taxpayers’ attention on the design of limited risk arrangements

Nélio B Weiss

In the March edition of the magazine, Johann Muller, a member of the Danish Competent Authority for transfer pricing (TP), wrote about the issues that need to be addressed when looking at examples 1 and 2 to Annex C of the OECD Base Erosion and Profit Shifting (BEPS) report. Now, he proposes a simplified transfer pricing documentation process for vertically integrated multinational enterprises (MNEs). Both articles are written on a personal level and do not reflect the views of the Danish government.