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NERA opens transfer pricing office in Paris

Pim Fris: NERA now in the main markets in Europe Emmanuel Llinares: Transfer pricing experience from Andersen and Fidal NERA Economic Consulting, a global economic analysis firm, has opened a transfer pricing office in Paris. The group in Paris forms part of the firm's global transfer pricing team which has offices in a number of major business centres around the world.

December 01 2005

Authorities scrap lump-sum expense deductions

Swiss companies and Swiss permanent establishments of foreign companies, which up to now were able to apply a lump-sum expense deduction for foreign-foreign business transactions, must in future:

December 01 2005

Tax authorities take on the treaty shoppers

Jeffrey Trossman and Amanda Heale of Blake, Cassels & Graydon discuss how the Canada Revenue Agency is challenging transactions that seek to benefit from treaty shopping and analyze the approach of the courts on the issue

December 01 2005

Intangibles: How analysis can define the nature, use and pricing of intangibles

By Pim Fris and Sebastian Gonnet, NERA Economic Consulting

December 01 2005

China: Cross-border IP transactions and transfer pricing planning

By Philip Anderson and Banny Lam, Ernst and Young

December 01 2005

Brand valuation: How to use transfer pricing to calculate the value of a brand

By Alexander Voegele, Stuart Harshbarger, and Nihan Mert-Beydilli, NERA Economic Consulting

December 01 2005

Editorial

How to price intangibles continues to challenge tax executives in a wide range of industries. Doing so in a way that satisfies tax authorities around the world is a burden, especially as administrators are well aware now of the value of intangibles on company balance sheets. Tax executives need to update themselves regularly on best international practice.

December 01 2005

Anti-inversion rule threatens foreign tax structuring plans

The anti-inversion provisions enacted in 2004 tax legislation are overly broad and may result in significant adverse income tax consequences for many internal restructurings within an affiliated group of corporations, argues Kevin Rowe of Alston & Bird

December 01 2005

Holding companies are key international tax planning tool

A German holding structure is a significant instrument in tax planning and can increase shareholder value by minimizing the tax burden on overseas earnings and profits, believe Dieter Endres, Christoph Schreiber and Pia Dorfmueller of PricewaterhouseCoopers

December 01 2005

How foreign investors can buy German companies tax efficiently

A foreign investor needs to plan the structuring of the acquisition of a German company carefully to achieve tax efficiencies, explain Andreas Schumacher and Jochen Bahns of Flick Gocke Schaumburg

December 01 2005

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