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Rajendra Nayak Ganesh Pai The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of Western Union Financial Services Inc. vs. ADIT [2007] 291 ITR (AT) 176 examined the taxability of a foreign company carrying out money transmission services. The taxpayer, a tax resident of US, was a company incorporated in the US and was engaged in the business of rendering money transfer services across international borders. For its activities in India, the taxpayer appointed agents in India who were compensated by way of commission.

Changes to the Irish tax credit system – foreign branches The Finance Act 2007 introduced significant changes to the tax credit system for Irish companies operating through an overseas branch. The new measures provide for the introduction of an Irish tax credit for taxes equivalent to corporation tax and capital gains tax paid by a branch in a country with which Ireland does not have a tax treaty or where the tax treaty provides no relief for such taxes.

Jacek Bajger (Poland), Keval Doshi (India), Thomas Herr (US), Julian Hong (China) and Geoff Soh (Singapore) of KPMG discuss transfer pricing issues for emerging markets

By Rolf Heinrich (Germany), Andrew Hickman (UK), Pascal Luquet (France) and Steven Tseng (China) of KPMG

Sponsored Americas piece by Alan Granwell and Eric Ryan of DLA Piper US

Sixth VAT Directive – Article 28c(A)(a), first subparagraph – Intra-Community supplies – Exemption – No obligation on the tax authorities to gather evidence – Directive 77/799/EEC – Mutual assistance between the competent authorities of the member states in the area of direct and indirect taxation – Regulation (EEC) No 218/92 – Administrative cooperation in the area of indirect taxation.

Sixth VAT Directive – First subparagraph of Article 28a(3) and first subparagraph of Article 28c(A)(a) – Intra-Community acquisition – Intra‑Community supply – Exemption – Goods dispatched or transported to another member state – Evidence – National measures to combat fraud.

Sixth VAT Directive – First subparagraph of Article 28c(A)(a) – Intra-Community supply – Refusal of exemption – Belated production of evidence of the supply.

Bowen to run US TP practice

Gabriela Villavicencio and Armando Cabrera, of Baker & McKenzie, look how Argentina's transfer pricing rules have developed since their introduction in 1998