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A Closer Look GLOBAL TAX WEEKLY ISSUE 102 | OCTOBER 23, 2014 a closer look SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL FISCAL GOVERNANCE BUDGETS COMPLIANCE OFFSHORE SECTORS MANUFACTURING RETAIL/WHOLESALE INSURANCE BANKS/FINANCIAL INSTITUTIONS RESTAURANTS/FOOD SERVICE CONSTRUCTION AEROSPACE ENERGY AUTOMOTIVE MINING AND MINERALS ENTERTAINMENT AND MEDIA OIL AND GAS COUNTRIES AND REGIONS EUROPE AUSTRIA BELGIUM BULGARIA CYPRUS CZECH REPUBLIC DENMARK ESTONIA FINLAND FRANCE GERMANY GREECE HUNGARY IRELAND ITALY LATVIA LITHUANIA LUXEMBOURG MALTA NETHERLANDS POLAND PORTUGAL ROMANIA SLOVAKIA SLOVENIA SPAIN SWEDEN SWITZERLAND UNITED KINGDOM EMERGING MARKETS ARGENTINA BRAZIL CHILE CHINA INDIA ISRAEL MEXICO RUSSIA SOUTH AFRICA SOUTH KOREA TAIWAN VIETNAM CENTRAL AND EASTERN EUROPE ARMENIA AZERBAIJAN BOSNIA CROATIA FAROE ISLANDS GEORGIA KAZAKHSTAN MONTENEGRO NORWAY SERBIA TURKEY UKRAINE UZBEKISTAN ASIA-PAC AUSTRALIA BANGLADESH BRUNEI HONG KONG INDONESIA JAPAN MALAYSIA NEW ZEALAND PAKISTAN PHILIPPINES SINGAPORE THAILAND AMERICAS BOLIVIA CANADA COLOMBIA COSTA RICA ECUADOR EL SALVADOR GUATEMALA PANAMA PERU PUERTO RICO URUGUAY UNITED STATES VENEZUELA MIDDLE EAST ALGERIA BAHRAIN BOTSWANA DUBAI EGYPT ETHIOPIA EQUATORIAL GUINEA IRAQ KUWAIT MOROCCO NIGERIA OMAN QATAR SAUDI ARABIA TUNISIA LOW-TAX JURISDICTIONS ANDORRA ARUBA BAHAMAS BARBADOS BELIZE BERMUDA BRITISH VIRGIN ISLANDS CAYMAN ISLANDS COOK ISLANDS CURACAO GIBRALTAR GUERNSEY ISLE OF MAN JERSEY LABUAN LIECHTENSTEIN MAURITIUS MONACO TURKS AND CAICOS ISLANDS VANUATU GLOBAL TAX WEEKLY a closer look Global Tax Weekly – A Closer Look Combining expert industry thought leadership and team of editors outputting 100 tax news stories a the unrivalled worldwide multi-lingual research week. GTW highlights 20 of these stories each week capabilities of leading law and tax publisher Wolters under a series of useful headings, including industry Kluwer, CCH publishes Global Tax Weekly –– A Closer sectors (e.g. manufacturing), subjects (e.g. transfer Look (GTW) as an indispensable up-to-the minute pricing) and regions (e.g. asia-pacifi c). guide to today's shifting tax landscape for all tax practitioners and international fi nance executives. Alongside the news analyses are a wealth of feature articles each week covering key current topics in Unique contributions from the Big4 and other leading depth, written by a team of senior international tax fi rms provide unparalleled insight into the issues that and legal experts and supplemented by commentative matter, from today’s thought leaders. topical news analyses. Supporting features include a round-up of tax treaty developments, a report on Topicality, thoroughness and relevance are our important new judgments, a calendar of upcoming tax watchwords: CCH's network of expert local researchers conferences, and “The Jester's Column,” a lighthearted covers 130 countries and provides input to a US/UK but merciless commentary on the week's tax events. GLOBAL TAX WEEKLY ISSUE 102 | OCTOBER 23, 2014 a closer look CONTENTS FEATURED ARTICLES Transfer Pricing In Israel: A New Frontier Defense For Transfer Pricing: Profi ts Of A Hong Jonathan Lubick and Nimrod Jagel-Cohen, Kong Procurement Company affi liated with Economics Partners LLC 5 Dr. Alexander Voegele and Philip de Homont, NERA Economic Consulting 39 HNWIs Residency Comparison Chart M/Advocates of Law 10 Topical News Briefi ng: Playing To Win Th e Global Tax Weekly Editorial Team 43 New Developments Regarding Th e Corporate Tax Reform III In Switzerland Key Changes To Company Law In India Walter H. Boss, Poledna Boss Kurer AG 21 Padmini Khare Kaicker and Himanshu Chapsey, B.K. Khare & Co., India, an independent member Topical News Briefi ng: Defi cit. Debt. Denial! of Morison International 44 Th e Global Tax Weekly Editorial Team 28 BEPS: Undermined By Unilateralism? Stuart Gray, Senior Editor, Global Tax Weekly 29 NEWS ROUND-UP Country Focus: Ireland 49 Budgets 53 American Firms Hail Irish Budget Announcements Italian Cabinet Approves 2015 Tax Cuts Ireland Cuts Individual Income Tax Burden Portugal's 2015 Budget Contains Corporate Tax Cut In 2015 Budget South Africa Defers Certain Budget Tax Measures Kenny: Marginal Tax Rate Will Fall To 50 Percent In 2016 International Tax Planning 55 International Trade 64 Wyden Pushes US Tax Reform As Inversion Activity Slows US Calls For Greater Japanese Ambition On TPP AbbVie To Pull Out Of Merger With Shire WTO Chief Pushes For Trade Facilitation Pact Breakthrough Seychelles Agrees Terms Of WTO Accession 57 Country Focus: Switzerland EU Reaches Trade Deal With East African Community Switzerland To Fill Argentinian Double Tax Treaty Void Switzerland, EU Finalize Agreement On Corporate Tax Reform TAX TREATY ROUND-UP 68 Italy, Switzerland DTA Talks Proceeding, Despite Problems CONFERENCE CALENDAR 69 Switzerland Extends Olive Branch To India On Tax IN THE COURTS 78 Compliance Corner 60 THE JESTER'S COLUMN 86 UK Taxpayers' Rights Under Siege, Says CIOT President Th e unacceptable face of tax journalism European Commission Reports On Progress To Cut Red Tape UK Tax Gap Widens Austria Given Extra Year To Automatically Exchange Tax Data For article guidelines and submissions, contact [email protected] FEATURED ARTICLES ISSUE 102 | OCTOBER 23, 2014 Transfer Pricing In Israel: A New Frontier by Jonathan Lubick and Nimrod Jagel-Cohen, affi liated with Economics Partners LLC Contact: [email protected] ; Tel: (+972) 9-772-4233 Transfer pricing controversy cases being examined international consensus on many of these issues, at all levels by the Israel Tax Authority ("ITA") have many of the cases under transfer pricing examina- risen over the past two to three years, while the ITA's tion by the ITA have become protracted; however, ability to settle these cases with multinational com- it must be noted that some of these cases are settled panies appears to be an increasingly more diffi cult in the normal examination process. A review of and protracted process. One of the bases for the in- some of the leading transfer pricing examination crease in ITA transfer pricing examination cases is issues which multinational corporations are facing the relatively recent issuance of its transfer pricing in Israel is highlighted herein, together with a brief regulations and its attendant circular (2009), the review of specifi c ITA approaches to various issues obligation to fi ll in a special tax form for transfer relating to transfers of intangibles. pricing purposes that requires itemization of inter- company transactions (Form 1385, 2008), and a Israel Start-Up Background circular on business conversions in the high tech- Prior to highlighting the contentious transfer pric- nology sector (2010). Further, with Israel's entry ing issues under examination in Israel, a brief review into the OECD in 2010, the ITA's transfer pricing of the economy itself is provided as background that department in particular has relied on the resourc- forms a basis on which transfer pricing examinations es provided by the OECD regarding training and are conducted. Many articles, as well as a book, have audit procedures to enable itself to gain the tools been written, documenting the Israeli economy's necessary to perform transfer pricing examinations. entrepreneurial nature and its success in the creation of start-up companies. A recent article published on- On the examination level, given the large num- line by Forbes notes: " Israel, it turns out, is quite good ber of mergers and acquisitions ("M&A") of Is- at coming up with creative ideas, starting up compa- raeli-based companies, some of the more sensitive nies, raising early stage funding, and exiting these small transfer pricing issues with respect to intangibles companies [less than USD100m]. " 1 By contrast, what are coming to the forefront. Due to the lack of Israel has yet to achieve is the creation of a growing 5 number of larger multinational entities which do generally speaking, from the success of the entire not seek exits and whose base remains in Israel. Th e Israeli entrepreneurial economy. However, it must same Forbes article noted above highlights this fact: be noted that there is never a guarantee that the " What Israel hasn't demonstrated is that it can build actual buy-out itself becomes a success for the ac- bigger, lasting fi rms." quiring entity. Herein also lies one of the primary issues which the Th e issuance of the business conversion circular in Israeli government and the ITA are confronting; 2010 was a means to enable the ITA to not only many of these Israeli start-up companies have not tax entities which are acquired and where there is been taxpayers as they are still in the business build- therefore a deemed transfer of intangibles, but to ing stage. Th eir business, like that of many world- also provide the framework for taxing Israeli enti- wide start-up companies, has focused on creating a ties which perform a business restructuring from viable technology/intellectual property ("IP") base within when there is no distinct exit. and beginning to commercialize their product. As a result, the entire business usually records losses Israel's Transfer Pricing Background during this start-up period. Further, a signifi cant And Examination Activity number of M&A exits have, historically, been re- Th e ITA transfer pricing department, since the is- lated to Israeli entities whose product may not have suance of transfer pricing
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