For editorial matters, contact Sophie Ashley, editor, International Tax Review,ITR Premium and TPWeeksashley@euromoneyplc.com +44 20 7779 8339

For subscription enquiries, contact Nick Burroughs, subscriptions managernburroughs@euromoneyplc.com +44 20 7779 8379

BRICS TAX COOPERATIONSPECIAL FOCUS

Next pagewww.internationaltaxreview.com Page 1BRICS Special

International Tax Review provides taxpayers with in-depth analysis of developments in Brazil, Russia,India, China and South Africa (BRICS), along with the rest of the world.

January 2013

ContentsBRICS’s tax authorities promise to share information

BRAZIL: Tax incentives related to the Olympic and Paralympic Games

RUSSIA: Why guidance on controlled transactions is a headache

INDIA: Chidambaram confirms GAAR delay until 2016

CHINA: SAT to incorporate country UN chapter into circulars

SOUTH AFRICA: Re-characterisation of tax exempt dividends as taxable income

How BRICS can impact your transfer pricing

By Sophie Ashley and Matthew Gilleard

The BRICS countries' (Brazil, Russia,India, China and South Africa) taxauthorities have agreed to shareinformation to strengthen their taxsystems, including India helping SouthAfrica to implement an advance pricing(APA) regime.

In a communiqué released last week, by IndianFinance Minister P Chidambaram, the BRICS

committed to sharing their experience of bestpractice, capacity building, anti-avoidance andnon-compliance practices and effectiveexchange of information.

The countries promised to share resourcesand knowledge and to also extend cooperationin tax administration in a way that will benefitpeople living in BRICS countries.

The five heads of revenue met in Delhi onJanuary 17 and 18.

Information sharing with treaty partnersChidambaram’s announcement of greaterBRICS convergence on tax matters comes in thesame week as India’s Central Board of DirectTaxes (CBDT) released an instruction whichcontains guidelines on the sharing of informa-tion among treaty partners (covering inboundand outbound requests).

Highlights of the new guidelines include aprovision that requests for exchange of informa-tion should not be generic.

“The information should be sought in elab-orative and specific manner,” says the manual,which also has a provision allowing two or more

countries to conduct a joint auditif related persons are engaged incross-border activities.

And Rafael Santiago Lima, fromthe Division of InternationalAffairs of the Undersecretariat ofExamination at the BrazilianReceita Federal, also this weekconfirmed that Brazil is altering theway it handles data receivedthrough information exchangeagreements. He said such informa-tion should be constantly looked atand examined.

“Brazil is changing its system ofdealing with the information andhow it is used. Reforms are on theway,” he said.

South Africa and India Among those in the meeting wasSouth African Revenue Service’s(SARS) Commissioner, OupaMagashula.

“BRICS cooperation must notbe viewed in isolation,” said aspokesman for SARS. “It shouldbe noted that South Africa haslong established relations withBrazil and India bilaterally,through the IBSA (India, Brazil,South Africa) Heads of RevenueAdministration Working Groupand multilateral fora such as theUN, World CustomsOrganisation, [and the OECD] Global Forumon Transparency and Exchange of Informationfor Tax Purposes, the Task Force on Tax andDevelopment and the Task Force on TaxCrimes and other Crimes.”

The revenue authority said though BRICScooperation will not duplicate IBSA, the lessonslearnt through IBSA cooperation will no doubtserve as a good foundation for taking forwardBRICS cooperation.

SARS said it intends to send its officials fortraining with other BRICS partners and willreceive their officials in return.

Explaining what SARS will bring to thetable, the spokesman said: “SARS distinguishes

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 2BRICS Special

BRICS’s tax authorities promise to share information

between technical (negotiating) skills, function-al (implementation) skills and social skills (intra-organisational and wider cross-government andinternational cooperation) and South Africa hasmuch experience in technical skills in the formof negotiating the Tax Information ExchangeAgreement (TIEA) as a bridge into Africa.”

“South Africa is particularly interested in theAPA regimes of fellow BRICS countries andthere is consensus to focus efforts on addressingthe practices resulting in the erosion of the taxbase,” the spokesman added.

Bucking the trendHowever, there are – in some aspects – vast dif-ferences between the BRICS’ tax systems. Brazildoes not adhere to the OECD transfer pricingguidelines and has a stand-out regime when itcomes to the rest of the world. Russia is gear-ing-up to join the OECD in the foreseeablefuture, though its decision is not at all definite.South Africa is also aligning itself far more close-ly with the OECD.

Because of this, TP Ostwal of TP Ostwal &Associates in India, who also drafted the Indiachapter in the UN’s practical manual for trans-fer pricing in developing countries, said: “I donot know the future of this alliance but I cancertainly say India, China and Brazil will comecloser in their cooperation.”

He added, however, that alliances like theBRICS are important if developed countries areto get their fair share of taxable profits.

“I don’t see any problem in such a move.This is inevitable if developing countries have tofight the developed countries’ forces and as suchall these [BRICS] countries are not likely to jointhe OECD. And, if they do join the OECD theywill have to change the rules of the game –those of source-based taxation principles.”

Thought leaderIndia is emerging as a benchmark for manyaspects of the other countries’ tax systems.Not only is it helping South Africa implementits APA regime, it is also a thought leader forChina.

“In practice, Chinese tax authorities mayhave followed the Indian practices in someareas, for example, to increase their expecta-tion on returns of contract R&D services,”said Annie Han , tax manager at Siemens inChina.

This commitment to work together couldbe good news for people living in the BRICS.Improved, more efficient, tax systems willmean more revenue and an improved societybut it is important the countries remain attrac-tive investment locations.

“It is good for BRICS countries to find thebest ways to deal with the unique issues theyface but not addressed by OECD guidelinesby sharing experiences. But taxpayers will notwant to see that the tax authorities becomemore aggressive in their tax positions throughalliance,” Han added.

India will also hope to gain from thealliance, especially while it is introducing itsgeneral anti-avoidance rule (GAAR).

“India is on the brink of adopting or imple-menting a GAAR, controlled foreign company(CFC) rules, branch profits tax and so on,”said Amit Singhania, of Amarchand &Mangaldas. “This forum provides scope forgreater deliberation, consensus building,cooperation and exchange of ideas and experi-ences between the developing countries onkey aspects of international taxation.”

Singhania believes the establishment of aformal, coordinated group for the BRICS todiscuss tax policy and administration signals a

levelling of the playing field between devel-oped and developing countries.

“Traditionally, developed and developingcountries have had different perspectives onissues relating to international tax policy. Mostauthoritative texts on international taxationhave emanated from the developed world.This initiative provides developing nations theopportunity to build consensus for their posi-tions on pertinent issues of international taxpolicy, such as source-based taxation, transferpricing and so on,” said Singhania.

Trouble ahead?However, some advisers have voiced concernsabout the BRICS nations pushing ahead withpolicies independently of the rest of the world.

Guillermo Teijeiro, of Teijeiro & BalloneAbogados, said he fears the BRICS being “tooproactive” by themselves.

Elina Castro, tax director at Alstom inArgentina, commented, via LinkedIn, that if therest of the BRICS follow Brazil’s transfer pricingpolicy and interpretation of double tax treaties,“we will have a lot of problems trying to har-monise international taxation with their view”.

Teijeiro agreed, adding that Brazilian CFCrules, the retrospective application of tax lawin India and the taxability of indirect sharetransfers in China, could also be added toCastro’s list.

The impact of the initiative, said Singhania,“will largely depend on the seriousness withwhich it is pursued”.

“It will be interesting to see whether theBRICS countries release a model conventionor policy papers for proposing a united fronton behalf of the developing world on interna-tional tax issues. In any case, the initiativeshould have a positive bearing on the coun-

tries’ concerns relating to effective exchangeof information and enforcement of taxationlaws,” said Singhania.

Among BRICS countries, some of thehighlights of cooperation in both customsand tax include:

2008Brazil hosted an IBSA risk management sem-inar in October 2008.

India hosted IBSA seminars on customsvaluation as well as transfer pricing inNovember 2008.

2011South Africa hosted an IBSA tax evasion andavoidance seminar in August 2011.

South Africa hosted an IBSA meeting ofcustoms technical experts on exchange ofinformation in September 2011.

SARS hosted two five-day training pro-grammes for cadets from the India NationalAcademy of Direct Taxes (NADT) in Marchand September 2011.

2012India hosted South Africa for a two-weekstudy visit focussing on transfer pricing inJanuary 2012.

China hosted South Africa for a trainingseminar on border management and securityin November 2012.

2013SARS and South Africa will host a furtherNADT training group in 2013 and SARSplans to visit India to benchmark theiradvanced pricing agreement (APAs) regime.

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 3BRICS Special

By Nélio Weiss and Philippe Jeffrey, PwC

On October 10 2012, the Brazilian govern-ment published Provisional Measure (PM)

584, providing for tax measures applicable tooperations involving the organisation or realisa-tion of events directly related to the 2016Olympic and Paralympic Games to be held in Riode Janeiro.

The PM provides for the exemption of federaltaxes due on import of goods or services usedexclusively in activities directly related to theorganisation or realisation of both events, such as:trophies, medals, plaques, statuettes, pins andbadges, flags and other commemorative objects;promotional material, flyers and the like; andother similar non-durable material (up to oneyear). Taxes included in this exemption are the II(import tax); IPI (excise duty) over imports dueon customs clearance; PIS/COFINS-Import;among other charges and duties.

Non-resident individuals entering Brazil with atemporary visa, employed or contracted by theabove organisations to carry out activities relatedto the events’ organisation, are exempt of individ-ual income tax (IRPF).

Furthermore, the International OlympicCommittee (IOC) and RIO 2016 (OrganisingCommittee) are exempt from a number of fed-eral taxes, such as the IRPJ (corporate incometax), the IRRF (withholding income tax), theIOF (tax on financial transactions), the IPI(excise tax), the social contribution on net prof-its (CSLL), the PIS/COFINS-Import and thecontribution for the intervention in the eco-nomic domain (CIDE). With regards to RIO2016, the IRRF exemption applies to incomepaid, credited, delivered, used or remitted by orfor this entity, regarding the supply of goods orservices.

The PM also provides for the exemption of IPIand PIS/COFINS in the acquisition of goods andservices in the local market used in the organisa-tion or realisation of the events.

To enjoy these benefits, the IOC and associat-ed companies, the Court of Arbitration for Sport(CAS), the World Anti-Doping Agency (WADA),National Olympic Committees, InternationalSporting Federations, media companies andaccredited transmitters, sponsors, IOC and RIO2016 service providers must be established inBrazil if they commercialise products or services inBrazil or employ individuals with or without a for-

mal employment relationship, even if only fororganising or realising the games.

The IOC and RIO 2016 shall provide a list tothe Brazilian Revenue Service including the indi-viduals and legal entities that shall be entitled tothe tax benefits mentioned above. Further regula-tion is expected in due course.

As a general rule, a PM is issued by theExecutive Branch of the Federal Governmentand has the effect of law while it is analysed bythe Brazilian Congress, that can approve (withamendments or not) or reject it. This processshould take place within a 60-day period, a term

that may be extended for an additional 60-dayperiod. If Congress does not act within this120-day period, the PM expires and loses effec-tiveness. If approved without amendments, theabovementioned measures shall apply to taxableevents occurring from January 1 2013 toDecember 31 2017.

Nélio Weiss (nelio.weiss@br.pwc.com) & Philippe Jeffrey(philippe.jeffrey@br.pwc.com)PwCTel: +55 11 3674 2271Website: www.pwc.com

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 4BRICS Special

BRAZIL Tax incentives related to the Olympic and Paralympic Games

By Joe Dalton

Russia’s Ministry of Finance has clarifiedhow taxpayers should calculate thethreshold for controlled transactions, butits interpretation leaves companies witha choice of non-compliance ordedicating more resources to transferpricing.

S ince Russia’s new transfer pricing rules werereleased last year, there has been much debate

over how they should be applied.The threshold value for domestic related party

transactions to qualify as controlled is RUB3 bil-lion ($103 million).

Taxpayers can determine whether a transactionexceeds the threshold by considering the aggre-gate income of all transactions between pairs ofrelated companies.

Or, as the ministry stated in a recent letter, tax-payers can make calculations based on the sum ofall transactions performed with all related partiesin a year.

Under the ministry’s interpretation, if aRussian parent company provides services, loans,or sells goods to a subsidiary, and the total incomereceived is below the threshold, those transactionscould still be classed as controlled if income fromtransactions with all other subsidiaries in thegroup takes the total above the threshold.

The tax authorities can request transfer pricingdocumentation for all controlled transactions,which must be provided by taxpayers within 30days of receiving the request.

The authorities will then be able to make trans-fer pricing adjustments if they decide the transac-

tions do not meet with arm’slength standards.

A transfer pricing directorfor a Russian oil company,who wished to remain anony-mous, said if the principle ofcalculating the overall incomeof all transactions with allrelated parties is enforced,the number of controlledtransactions may radicallyincrease.

“The more controlledtransactions we have, themore money we spend ontransfer pricing staff andother supplementary servic-es,” said the director.

“The chance of not filingthe notification on time willalso increase and that maylead to a transfer pricingaudit,” the director added.

Evgenia Veter, of Ernst &Young, said taxpayers mustnow decide to what extentthey want to follow the min-istry’s recommendations andwhat risk there will be if theydo not.

“Companies will need to assess the risk ofnot documenting some transactions againstthe cost of being completely compliant,” saidVeter. “To be fully compliant taxpayers willneed to spend a lot of time and money onpeople and management services to preparetransfer pricing documentation for even verysmall transactions.”

“Taxpayers will still want to prepare docu-mentation for more sensitive transactions but

may be willing to accept some risk to avoid thecost of documenting every transaction,” sheadded.

It is questionable whether the tax authori-ties will actually have the resources to auditsuch a greatly increased number of controlledtransactions.

However, the possibility of disputes arisingif taxpayers do not follow the guidance will behigh.

Veter said the tax authorities seem to be tryingto find the safest answer from a legislative or tech-nical perspective but this is not always practical.

“In the medium term, the ministry’s opinionmust be taken into account by those taxpayerswho are planning their intra-group arrangements,for example, considering setting up a shared serv-ices centre, and providing uniform transactions byone group member to other members,” saidSvetlana Stroykova, of PwC.

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 5BRICS Special

RUSSIA Why guidance on controlled transactions is a headache

By Matthew Gilleard

Indian Finance Minister, P Chidambaram,confirmed today that the majorrecommendations of the expert generalanti-avoidance rule (GAAR) committeewill be accepted and that GAARimplementation will be deferred by twoyears until 2016.

Foreign investors are cheering the news,which sees the legislative change pushed

back from its original implementation date ofApril 1 2014.

Most of the other recommendations made bythe Parthasarathi Shome-led expert committeewere also accepted, including requirementsregarding the make-up of the GAAR ApprovingPanel, the transaction value threshold for GAARto be invoked, and a softening of the GAARapplication criteria so that obtaining a tax bene-fit must be the main purpose for an arrange-ment, rather than “the main purpose or one ofthe main purposes” as previously worded.

“The modifications we have done are fair,non-discriminatory, just and strike a balancebetween interest of revenue and interest ofinvestors,” said Chidambaram.

“The decisions [contained in today’sannouncement regarding GAAR modifications]have by and large addressed the concerns thatwere expressed by investors,” he added. “Mostof the apprehensions I think have been removednow.”

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 6BRICS Special

INDIA Chidambaram confirms GAAR delay until 2016

Source: World Economic Forum

By Sophie Ashley

The State Administration for Taxation(SAT) is intending to incorporate theChina chapter, an appendix in the UN’stransfer pricing manual, into tax circularsin an attempt to increase the amount ofcorporate tax it collects.

The intention was made clear in recentmeetings, according to Glenn de Souza of

Baker & McKenzie. However, the SAT isbelieved to be hesitant about issuing specificcirculars related to this area.

“We also hear that the GAAR rules maycontain reference to the UN concepts,” saidde Souza.

Ideas such as location specific advantages(LSA) feature heavily in the China chapter ofthe UN’s practical manual for transfer pricingin developing countries. There have beenreports of audit cases where LSAs have beenused aggressively to make a contract R&Dsubsidiary of a foreign company raise its mark-up rate to 15% (from 10%).

“A client pointed out that their IndianR&D centre had even lower costs than China,but the tax bureau said that India was not arelevant comparison because China wasunique, in that it manufactured the entirespectrum of products and R&D centres had tobe co-located where the manufacturing wastaking place,” said de Souza.

China is effectively saying that R&D cen-tres have to be located with manufacturingbut this is not in keeping with the realities ofbusiness.

In general, however, it seems taxpayers andtheir advisers agree with the concepts set outin the China chapter, predominantly China’sstanding in terms of location savings and mar-ket premiums and why these issues make

China different to other countries when com-panies put together their transfer pricing doc-umentation.

“It raises a lot of relevant points,” saidHenrik Hansen of Ernst & Young. “What

would be welcome are clear definitions ofwhat SAT sees as a market premium and alocation saving, including how they willapproach these concepts. Taxpayers needthese concepts in order to comply.”

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 7BRICS Special

CHINA SAT to incorporate country UN chapter into circulars

By Peter Dach, ENS Taxand

In relation to the Taxation Laws AmendmentBill 2012, to avoid the re-characterisation of

dividends as income in the hands of the share-holder it is important:• that there is no obligation on the issuer of

the shares to redeem the shares withinthree years; and

• that there is no option of the shareholderto redeem the shares within three years.It is also necessary to ensure that the shares

are not secured by a financial instrument andare also not subject to an arrangement interms of which a financial instrument may notbe disposed of by the issuer. It should there-fore be ensured that there is no negativepledge in relation to any financial instrumentheld by the issuer.

Even if the relevant triggers are met, thedividends will still not be re-characterised astaxable income provided the shares are issuedby the issuer for the purpose of acquiringequity shares in an operating company.

In terms of the new section 8EA, any divi-dend received by or accrued to a person dur-ing any year of assessment in respect of a sharemust be deemed in relation to that person tobe an amount of income (and not a taxexempt dividend) if that share constitutes a“third-party backed share” at any time duringthat year of assessment.

A “third-party backed share” is defined insection 8EA(1) as any share in respect ofwhich an enforcement right is exercisable oran enforcement obligation is enforceable as aresult of any amount of any specified dividendor return of capital attributable to that sharenot being received by or accruing to the per-son holding the share.

An “enforcementobligation” is definedin section 8EA(1) as, inrelation to a share, anyobligation, whetherfixed or contingent, ofany person other thanthe issuer of the shareto:i) acquire the share

from the holder ofthat share;

ii) make any payment inrespect of that sharein terms of a guaran-tee, indemnity orsimilar arrangement;or

iii)procure, facilitate orassist with any acqui-sition or the makingof any payment con-templated in (i) or(ii) above.An “enforcement

right” has similar word-ing to the concept of an“enforcement obliga-tion”.

In terms of the pro-viso to the definition ofa “third-party backedshare”, where the purpose of the issuer in issu-ing the preference shares is to acquire equityshares in an operating company, then the re-characterisation of dividends as taxableincome does not take place. This is providedthat the enforcement right or enforcementobligation may be exercised against any com-pany that forms part of the same group of

companies as the issuer and operating compa-ny respectively.

It can therefore be seen that there are fairlycomplex rules relating to the re-characterisationof tax exempt dividend income to taxable incomein respect of certain shares. These rules apply inrespect of existing shares and therefore it shouldbe ensured that, at the relevant effective dates,

the above-mentioned triggers are not in place inrespect of all such shares.

Peter Dachs (pdachs@ens.co.za)ENS TaxandTel: +27 21 410 2500 Fax: +27 21 410 2555Website: www.ens.co.za

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 8BRICS Special

SOUTH AFRICA Tax exempt dividends as taxable income

By Sophie Ashley

The BRICS are steadily earning theirplace in international transfer pricingpolicy. With strong economies,investment in and out of the BRICS isconstantly growing.

The BRICS often need careful handling,however. They represent almost three bil-

lion people, with a combined nominal GDP of$13.7 trillion. The tax administrations areaggressive in protecting the countries’ rev-enues but their staff can lack in experience.

None of the BRICS are OECD-membercountries (though they are all involved in taxpolicy discussions to differing extents) buttheir strong economies and attractive invest-ment opportunities mean they have a relative-ly strong presence in OECD discussions.

Antoine Glaize, the global head of transferpricing for Taxand, based in Paris, said,because of the BRICS’ separation from theOECD, the biggest concerns for taxpayersinclude “limitation of certain intangible pay-ments, application of withholding tax on serv-ices, normative rules for local returns anddifficulties [for authorities ]to explain transferpricing policies changes even [those] well doc-umented”.

Double taxation is a constant threat andrepresents the biggest headache for taxpayers.

“Brazil effectively ignores arm’s-lengthprinciples and instead mandates arbitraryresults according to the taxpayer’s functionalprofile,” said Michael Leonowitz, global trans-fer pricing leader and head of Americas taxes atSABIC, a manufacturing company.

“Comparability, reliability and industrydynamics are not properly taken into account.China, too, seeks to justify local profits, no matterwhat, by asserting vague notions of location sav-ings and market premium, asserting such valuedrivers automatically accrue to China itself,” headded.

Despite the BRICS’ non-membership at theOECD, the organisation is still considered thebiggest influencing factor in their tax policy. “Thissingle organisation has been extremely proactivein publishing needed guidance – non-binding – totaxpayers and tax authorities and is providingthought leadership on emerging issues,” saidLeonowitz.

Because these coun-tries are in a stage of relatively new advanced eco-nomic development, there are other, stronger,factors at play in terms of driving transfer pricingdevelopment but the BRICS do play a part.

“While BRICS may have viewed transfer pric-ing as a potential threat for them and symmetri-cally have adopted very aggressive positions, theytend to soften their approach and to convergetowards international standard rules even thoughfield practice may remain far from MNEs expecta-

tions,” said Glaize.Leonowitz said the China

and India are particularly aggres-sive by challenging the application of

traditional transfer pricing methodolo-gies and positing creative arguments not pre-

viously addressed such as China’s location savings.“Such debates are healthy, I think, to the extentthe tax authorities remain open minded in tack-ling these interesting, thorny questions. The othercountries do not yet exert much influence. Thetransfer pricing environment in Russia and SouthAfrica is simply too new; Brazil is too arbitrary.”

Complying with each of the BRICS in turnrequires a balance between local country law andreconciling against the other party to such trans-actions, which typically accept the arm’s-lengthprinciple and OECD guidelines.

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 9BRICS Special

How BRICS can impact your transfer pricing

With a subscription to ITR Premium you will gain access to International Tax Review magazine, research tools, databases and newsletters. Plus you will benefit from additional focused,targeted and in-depth articles on the tax areasthat matter to you:

To gain access email Nick Burroughs on nburroughs@euromoneyplc.comwww.itrpr w.internationaltaxreview.com

SUBSCRIBE NOW

Giving you the daily, in-depth news coverage you need

Corporate Tax Compliance Management

Tax Disputes Indirect Tax

ITR Premium Advert 1-2 page.indd 1 13/02/2012 14:20

With a subscription to ITR Premium you will gain access to International Tax Review magazine, research tools, databases and newsletters. Plus you will benefit from additional focused,targeted and in-depth articles on the tax areasthat matter to you:

To gain access email Nick Burroughs on nburroughs@euromoneyplc.comwww.itrpr w.internationaltaxreview.com

SUBSCRIBE NOW

Giving you the daily, in-depth news coverage you need

Corporate Tax Compliance Management

Tax Disputes Indirect Tax

ITR Premium Advert 1-2 page.indd 1 13/02/2012 14:20

With a subscription to ITR Premium you will gain access to International Tax Review magazine, research tools, databases and newsletters. Plus you will benefit from additional focused,targeted and in-depth articles on the tax areasthat matter to you:

To gain access email Nick Burroughs on nburroughs@euromoneyplc.comwww.itrpr w.internationaltaxreview.com

SUBSCRIBE NOW

Giving you the daily, in-depth news coverage you need

Corporate Tax Compliance Management

Tax Disputes Indirect Tax

ITR Premium Advert 1-2 page.indd 1 13/02/2012 14:20

Contents Next pagePrevious pagewww.internationaltaxreview.com Page 10BRICS Special

Follow us on:

ARCHIVE EMAIL ONLINE MOBILE

www.tpweek.com

The market leading source of up to the minute information on transfer pricing issuesThe market leading source of up to the minute information on transfer pricing issues

Visit www.tpweek.com/FT to take your free trial today

Sign up for a one-week FREE TRIAL Call: +44 (0) 20 7779 8380Email: rspeight@euromoneyplc.com Online: www.tpweek.com/ft

Take a one week free trial to www.tpweek.com and get access to:

• All the latest global transfer pricing news and analysis

• Country by country guides• Exclusive interviews• Latest TP appointments

• Sector guides• TP Doctor Service• Rulings updates• Case studies

Contents Previous pagewww.internationaltaxreview.com Page 11BRICS Special