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Tax treaties generally provide that the business profits of a non-resident enterprise are taxable in a state only to the extent that the non-resident enterprise has a permanent establishment (PE) in that state to which such profits are attributable. The PE definition included in tax treaties thus provides a crucial threshold to determine whether a non-resident enterprise must pay income tax on its business income in another state, explain Jacques Sasseville and Edward Barret.

The effective implementation of the arm’s-length principle is closely linked to the availability of information. In transfer pricing, the asymmetry of information between taxpayers and tax administrations can be acute, potentially opening opportunities for BEPS. For this reason, the BEPS Action Plan stressed the need to enhance transparency in general, and for transfer pricing purposes in particular. Andrew Hickman, Samia Abdelghani and Paul Hondius explain these enhancements in the context of Action 13.

Dorina Asllani Ndreka An agreement for the avoidance of double taxation of income and capital taxes and the prevention of fiscal evasion, concluded between the Republic of Albania and the Republic of Kosovo, entered into force in March 2015 and will apply from January 1 2016.

Since the introduction of Indian transfer pricing regulations in April 2001, transfer pricing has become the most important international tax issue for businesses operating in the country, says Vatika Bhatnagar of Airtel India’s global transfer pricing team.

Petar Varbanov On March 26 2015, the Republic of Bulgaria and the United Kingdom of Great Britain and Northern Ireland signed a new Treaty for the Avoidance of Double Taxation (DTT) which will replace the DTT signed in 1987. The new treaty will introduce rules which differ considerably from the provisions now in force.

Chris Neil The debate regarding tax reform continues to dominate politics in Australia, with a number of alternative reforms being canvassed.

Read this month's special features for GCC - VAT and Intangibles

Germán Campos Kennett Fuenzalida Del Favero Double tax treaties (DTT) that follow the OECD's Model Tax Convention normally include the concept of 'beneficial owner' to determine the true owner of dividends, interests and royalties in order to apply special tax rates provided under such treaties.

Jean Marc Gagnon Alexandra Carbone In Amdocs Canadian Managed Services Inc. (ACMS), the Federal Court denied the Canada Revenue Agency's (CRA) request under section 231.7 of the Income Tax Act, Canada (Act) to compel ACMS to provide the CRA with documents and information requested in the course of a transfer pricing audit.

Sandra Benedetto Jonatan Israel The entry into force of the Chilean general anti-avoidance rules (GAAR) envisaged by Law No 20.780 effective as of September 30 2015, has made the Chilean Internal Revenue Service (IRS) take specific actions regarding the organisation of its personnel, to address the challenges set forth by the Chilean GAAR regarding tax assessment.