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Rajendra Nayak Ganesh Pai The Authority for Advance Rulings (AAR), in the case of K.T. Corporation (2009-TIOL-12-ARA-IT) and the Income-tax Appellate Tribunal (ITAT) in the case of Jebon Corporation (2009-TIOL-323-ITAT-Bang) have both recently examined whether the activities of a liaison office in India would constitute a permanent establishment (PE) under the provisions of the tax treaty between India and Korea. Under the provisions of the tax treaty, a PE is defined as not to include a fixed place of business engaged in carrying out preparatory or auxiliary activities.

Janne Juusela The Supreme Administrative Court ruled in its recent decision (KHO 64/2009) that a holding company established for the purpose of acquiring an industrial company, carrying no active business activities and having no employees was not deemed as a company carrying on private equity activities for Finnish tax purposes. This meant that the holding company was not entitled to deduct liquidation loss accrued from the liquidation of the acquired company. The fact that the company was established for the purpose of acquiring the industrial company and subsequent utilisation of the liquidation loss was taken into account in the ruling.

Sophie Stylianou Cyprus is considered a popular location for companies engaged in financing activities. No direct thin capitalisation rules are applicable, such as debt-to-equity requirements. Equally, from a transfer pricing perspective, as in cases of back-to-back financing transactions, the arm's length principle is applicable in Cyprus.

Given the economic recession and in trying to mitigate the impact in the Chilean market, the government approved a bill – law 20.326 - in January 2009 which included some tax incentives. The bill proposes a transitory elimination of stamp tax, a temporary reduction of provisional monthly prepayment (PMP) rate, a regime to promote employee training and an advanced refund of the surtax.

By International Tax Review

By David Stevenson

Brazil does not adhere to the arm's-length principle but that does not mean taxpayers can take their transfer pricing obligations lightly, warn Simone Dias Musa and Clarissa Machado

Thomas Pippos In June New Zealand and Australia signed a new double tax agreement (DTA) which is the culmination of more than a year's negotiations between the two countries.

What does the introduction of advance pricing arrangements mean for taxpayers in India?

In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing.