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In Chile, the rules technically follow the OECD guidelines, but Miguel Zamora and Ana Paula Güitrón say it is not clear whether this is true. Advisers still struggle to know which transfer pricing methods are allowed.

Rajendra Nayak Ganesh Pai The Mumbai Tribunal in the case of Airlines Rotables Ltd, UK, the taxpayer, adjudicated on the issue of whether maintenance of stock of goods, belonging to the taxpayer, by its Indian customer results in the taxpayer having a permanent establishment (PE) in India, under the India UK tax treaty. The taxpayer a UK company, entered into an agreement with an Indian aircraft operator, the customer, for providing certain support services for the customer's aircraft. The agreement required the taxpayer to repair the component when it became operationally unserviceable and to replace the component during the interim period. To ensure adequate availability of the components, the taxpayer maintained stock of such replacement components at the operational bases of the customer in India, as well as in the UK at the taxpayer's main depot. The customer held the component stock only as a bailee (delivery of goods without transfer of ownership) at all times. The issue in dispute was whether the maintenance of the component stock constitutes a PE of the taxpayer in India under the UK treaty. Under the UK Treaty, a PE can be constituted, among other things, through a fixed place of business where the business of the foreign enterprise is wholly or partly carried on (Basic Rule) or through a dependent agent acting on behalf of the foreign enterprise in India, maintaining a stock of goods from which he regularly delivers on behalf of the foreign enterprise (Agency Rule).

Andrés Edelstein Ignacio Rodríguez The Supreme Court of Justice issued an unpredictable opinion in mid-June in the Hermitage case questioning the constitutionality of the Argentine Minimum Notional Income Tax (MNIT).

Megan Lapwood and Mark Atkinson of Deloitte in Switzerland describe how cross guarantees and the overall flow of benefits derived within a multinational group from external funding may affect how guarantee fees should be charged.

Sergiy Melnyk of Salans in Ukraine describes how the new draft tax code in Ukraine constitutes a significant departure from previous international tax provisions in the country.

The value added tax travel service margin scheme involves complex issues that concern businesses of all types, Stephen Dale of Landwell & Associés investigates the progress being made and how Europe might better develop the legal framework in this area.

Janusz Lewandowski has vehemently denied plans for a EU-wide tax

Luxembourg's corporate tax rules have been changed to include a minimum flat rate of €1,500 ($2000) income tax, which will apply to entities whose activities are not subject to a business license or do not require the approval of a supervisory authority.

Alexander Skowronek and Nathalie Grenewitz of Luther-Taxand in Germany discuss the effect a landmark decision in a car insurance tax case will have on the wider insurance industry. Including diminishing the risk that the deductible borne by the policyholder will be subject to German premium tax.

Stephen Rogers of Nexia International member firm, Nexia Court & Company in Sydney, explains what private equity companies need to look out for in Australia.