text:
Almost every day, a new approach for enhancing GXP compliance is proposed, espoused, or encouraged. Yet, our industry continues to experience problems with non-compliance. Some of these result only in adverse publicity for the recipient, though some result in potentially serious safety issues for consumers.
Is there anything truly new that can help us assess potential GXP concerns and, thus, drive compliance enhancement? Perhaps not. Nonetheless, I would like to pose a new way of looking at compliance that can possibly stimulate a new way of looking at these issues. I call this the contrarian’s approach to enhancing GXP compliance. You may have heard of contrarian investors… individuals that invest in companies experience bad news. A contrarian is someone that opposes or rejects popular opinion. In the world of compliance, a contrarian is not apt to automatically believe all the good audit reports they receive or the good inspection history of the site. The contrarian’s approach to compliance involves looking for bad news, not merely looking for what is going well. The contrarian asks the truly hard questions of compliance.
Let’s look at a few questions that can stimulate the contrarian’s approach. Ask these example questions of your team to generate alternative viewpoints of your own current compliance position.
If we have a recall next week, what will be the issue that caused it? Could we prevent it today, if we knew it?
If two individuals in your lab wanted to dry lab results, how could they do it given your current systems and protection of data? What would we have to do to prevent it?
What will be the primary concern noted on the next Warning Letter your firm receives? Do we have to accept that this will happen or change we change the future if we act today?
If your only job was preventing the next batch failure, what actions would you take today? What would you do if your job was literally in the balance?
If an angry employee wanted to sabotage a batch of product by mislabeling a few units, how would they do it? Is it possible that one angry individual could destroy your reputation as a company?
If someone wanted to hide your next stability (or sterility or environmental) failure, how would they do it? What systems have to be defeated for an individual to hide an undesired result?
If an operator needed to make unauthorized and undetected changes to a manufacturing process, how would they do it? Can you devise systems to prevent it?
These are only example questions. You could develop your own depending upon your operations. However, the concept is simple… if you wanted to foil your systems, could you do it and, if so, how? Or, if something bad was going to happen, what would it be and could you prevent it now, if you knew it?
GXP compliance is much more than following a checklist. It involves thinking beyond the regulations and seeking deeper, more complex answers. When you actually believe all the good audit reports you get each month, you are failing to recognize the underlying potential for disaster that could await. Think about using the contrarian’s approach to identifying possibilities that until today have not been adequately considered.
← Life is simple… so, why do we make it so hard?

tokenized:
Almost every day , a new approach for enhancing GXP compliance is proposed , espoused , or encouraged . Yet , our industry continues to experience problems with non - compliance . Some of these result only in adverse publicity for the recipient , though some result in potentially serious safety issues for consumers .
 Is there anything truly new that can help us assess potential GXP concerns and , thus , drive compliance enhancement ? Perhaps not . Nonetheless , I would like to pose a new way of looking at compliance that can possibly stimulate a new way of looking at these issues . I call this the contrarian ’s approach to enhancing GXP compliance . You may have heard of contrarian investors … individuals that invest in companies experience bad news . A contrarian is someone that opposes or rejects popular opinion . In the world of compliance , a contrarian is not apt to automatically believe all the good audit reports they receive or the good inspection history of the site . The contrarian ’s approach to compliance involves looking for bad news , not merely looking for what is going well . The contrarian asks the truly hard questions of compliance .
 Let ’s look at a few questions that can stimulate the contrarian ’s approach . Ask these example questions of your team to generate alternative viewpoints of your own current compliance position .
 If we have a recall next week , what will be the issue that caused it ? Could we prevent it today , if we knew it ?
 If two individuals in your lab wanted to dry lab results , how could they do it given your current systems and protection of data ? What would we have to do to prevent it ?
 What will be the primary concern noted on the next Warning Letter your firm receives ? Do we have to accept that this will happen or change we change the future if we act today ?
 If your only job was preventing the next batch failure , what actions would you take today ? What would you do if your job was literally in the balance ?
 If an angry employee wanted to sabotage a batch of product by mislabeling a few units , how would they do it ? Is it possible that one angry individual could destroy your reputation as a company ?
 If someone wanted to hide your next stability ( or sterility or environmental ) failure , how would they do it ? What systems have to be defeated for an individual to hide an undesired result ?
 If an operator needed to make unauthorized and undetected changes to a manufacturing process , how would they do it ? Can you devise systems to prevent it ?
 These are only example questions . You could develop your own depending upon your operations . However , the concept is simple … if you wanted to foil your systems , could you do it and , if so , how ? Or , if something bad was going to happen , what would it be and could you prevent it now , if you knew it ?
 GXP compliance is much more than following a checklist . It involves thinking beyond the regulations and seeking deeper , more complex answers . When you actually believe all the good audit reports you get each month , you are failing to recognize the underlying potential for disaster that could await . Think about using the contrarian ’s approach to identifying possibilities that until today have not been adequately considered .
 ← Life is simple … so , why do we make it so hard ?


text:
Switzerland does not have a CFC regime. However, according to the case law of the Swiss Federal Supreme Court, companies with statutory seats located abroad, but who have little or no local substance and are effectively managed in Switzerland may be subject to Swiss income tax.
For finance companies, the maximum debt allowed is 6/7 of their total assets.
In addition, the FTA publishes annually safe harbour interest rates for loans granted to related parties.
Interest paid on debt exceeding the maximum debt allowed and interest rates exceeding the safe harbour interest rates are requalified as a hidden dividend if paid to a shareholder or a related party. Consequently, such interest is not a deductible expense for federal and cantonal income tax purposes and is subject to withholding tax at a rate of 35% (which may be reduced under a relevant tax treaty).
However, the rules set out above are merely safe harbour rules and allow the taxpayer to prove that different arm’s length debt-to-equity ratio and interest rates apply.
Swiss codified tax law contains very few rules relating to transfer pricing questions. As a general rule, Swiss law states that (i) expenses of a company must be commercially justified and (ii) profits not shown in the profit and loss statement of a company must still be included in its taxable profit.
Based on these general rules, Swiss tax authorities can correct intra-group transactions that are not at arm’s length. In determining whether an intra-group transaction is at arm’s length or not, the Swiss administrative practice generally follows the OECD transfer pricing guidelines.
As previously mentioned, the FTA publishes yearly rules regarding safe harbour interest rates for loans and advances between related parties, in various currencies. This publication provides for maximum rates regarding loans from the shareholders or related parties to the company, and minimum rates regarding loans from the company to shareholders or related parties.
It is possible to obtain an advance pricing agreement (‘APA’) with the Swiss tax authorities. In general, the cantonal tax authorities are competent for granting unilateral APAs, whereas bi- or multilateral APAs, as well as unilateral APAs regarding Swiss withholding tax, are negotiated with the involvement of the FTA.
The US has comprehensive CFC rules, which have been further expanded by TCJA to include a global minimum tax of 10.5% on most CFC profits of a US corporate shareholder.
Under longstanding CFC rules, a controlling US shareholder of a CFC is subject to current US taxation on any so-called Subpart F income of the CFC. Subpart F income is intended to capture what Congress perceived to be “tax haven” income, and thus includes certain interest, dividends, rents, royalties and gains, as well as certain income from sale of property and provision of services involving related parties. An exception to subpart F income is provided for income subject to a local country tax of at least 90% of US the corporate rate (now 18.9% = 90% * 21%).
In addition, the TCJA introduced a new category of income captured by the CFC regime – so-called “Global Intangible Low-Taxed Income” (GILTI). GILTI consists of all income of the shareholders’ CFCs that is not subpart F income (or eligible for certain limited exceptions), to the extent that such income exceeds a 10% return on the CFC’s investment in tangible assets used in its trade or business (measured by tax basis). GILTI is fully included in taxable income of the US shareholder on a current basis in each year, with a 50% deduction provided for US corporate shareholders that results in an effective US tax rate of 10.5%. Foreign tax credits are allowed against US tax on both subpart F income and GILTI.
The TCJA also added the US’s first comprehensive thin capitalization test through amended Code Section 163(j). As amended Section 163(j) limits interest deductions of corporations and other businesses to 30% of adjusted taxable income. New Code Section 163(j) applies to all debt, whether third party or intercompany, whether the lender is US or foreign, and regardless of the US corporation’s debt-equity ratio. “Adjusted taxable income” is defined generally as US taxable income without regard to interest expense, loss carryforwards, and for taxable years beginning before January 1, 2022, depreciation or amortization (i.e., EBITDA). After 2022, deductions for depreciation or amortization are no longer added back, so that interest expense is limited to 30% of EBIT. Interest expense deductions that are disallowed carry forward indefinitely.
As noted above, Code Section 482 and the regulations thereunder provide a comprehensive set of transfer pricing rules. In addition, strict liability penalties apply to transfer pricing adjustments in excess of certain thresholds, unless the taxpayers has maintained contemporaneous documentation with the filing of the original tax return in a form specified by the transfer pricing regulations.
Advanced Pricing Agreements (APAs) are available from the IRS on a prospective basis. In the case of transactions between the US Company and an affiliate in a treaty country, bi-lateral and multi-lateral APAs are also available involving the IRS and the other competent authorities.
The FTC provides for a CFC rule that constitutes an exception to the territoriality principle: only profits derived from activities carried out in France are taxable in France. According to this rule, profits realised by an entity, which is, directly or indirectly, more than 50%, owned by a French company and which is located in a privileged tax regime country, are deemed to be received by the French company in due proportion of the shares owned and therefore, are to be taxed in France. An entity is considered to be located in a privileged tax regime country if the effective corporate tax rate applied in this country is at least 50% lower than France’s.
the amount of interest paid to related parties exceeds the amount of interest received from related parties.
The portion of interest paid which exceeds the highest of the three set criteria is not deductible. These rules can be extended to interest borne with respect to a bank loan when certain guarantees have been granted by affiliated companies to the lender.
Anti-hybrid stipulation, which forbids the deduction of interests, if the creditor is not taxable, at least at 8.33% (i.e. 25% of the French CIT) on the financial proceeds.
The FTA applies the arm’s length principle: prices applied to transactions between related parties must be similar to prices that would have been agreed upon for transactions between independent companies. If not, the FTA may presume an indirect transfer of profits from the French company to its foreign affiliate and reassess its taxable income accordingly, that is to the extent of the amount deemed to have been unduly shifted. The burden of proof regarding an indirect transfer of profits lies with the tax authorities.
The rules aiming at limiting the deductibility of the interest should be deeply amended by the 2019 Finance Bill in order to transpose the Anti Avoidance Directive ('ATAD') into the French interest limitation regime. The Finance bill should limit the deduction of net financial charges (including debts subscribed with a Bank or a third party) to either 30 % of the entity's EBITDA or 3 million euros (if higher) with a calculation made at the group level. The "rabot" would be removed and the thin-capitalization rules would be deeply amended.
The FTC provides for the possibility of a bilateral advance pricing agreement between multinational companies and the tax authorities which would aim at fixing the transfer pricing method to be used in cross-border transactions.
The State Aid action has not dramatically changed the situation, but just increased the already thorough examination of the APA requests.
Interest paid to related parties located in a tax haven or privileged tax regime jurisdictions is deductible provided that the expenses are necessary and the debt with such related party does not exceed 30% of the Brazilian company’s equity.
Additionally, Brazil does also provide for CFC rules, which in general, impose taxation on undistributed profits from foreign controlled and affiliated companies. Accordingly, profits from foreign controlled companies should be considered deemed distributed to the Brazilian controlling company by December 31 of each calendar year. On the other hand, provided that some conditions are met, profits derived from foreign affiliates not located in tax haven or privileged tax regimes jurisdictions are only subject to taxation in Brazil when they are effectively distributed.
Moreover, Brazilian transfer pricing rules were enacted by Law 9,430/96 and its subsequent amendments. Such rules introduced transfer pricing controls, in order to avoid undervaluation of export prices, or overvaluation of import prices, for purposes of calculating corporate income taxes (Income tax – “IRPJ” - and Social Contribution on Profits Tax – “CSLL”). Transfer pricing rules are applicable to any import or export of goods, services and rights, performed between a Brazilian company and a related party abroad, or a party located in a tax haven or privileged tax jurisdiction.
There are five methods to calculate import transfer price, as well as there are four methods to calculate export transfer price. For import transactions, if the actual import price is higher than the calculated transfer price, the taxpayer cannot deduct the difference for purposes of IRPJ and CSLL. For export transactions, if the actual price is lower than the applicable transfer price, the difference shall be computed for IRPJ and CSLL purposes.
It is worth mentioning that the Brazilian transfer pricing rules differ from the OECD Guidelines related to the referred subject. Accordingly, Brazilian rules adopt fixed margins to calculate the transfer price, instead of the arm’s length principles.
Finally, please note that the transfer pricing rules do also apply to loan transactions between foreign related parties.
(iii) the income of the controlled foreign corporation is low-taxed, which means that the tax levied is below 25%.
However, the German CFC rules provide for an exemption for corporations which have their statutory seat or their place of effective management within the EU or EEA. Such corporations may prove that their business has economic substance, they exercises genuine commercial activities and adhere to the arm’s-length-principle. In that case, the EU/EEA corporations will not be deemed to constitute a controlled foreign corporation under the German CFC rules.
Germany operates a thin-capitalization regime, the so-called interest barrier rule. Generally, the interest barrier rule is applicable if the annual net interest expenses amounts to or exceeds EUR 3 Million. Under the interest barrier rule, the tax deductibility of interest expense on any debt of a company is restricted to the amount of the interest income plus 30% of the company’s EBITDA for tax purposes. The taxable EBITDA differs from the financial EBITDA because it is based on the taxable income of the company only. Therefore, any tax free income is not part of the taxable EBITDA. There are various exceptions and counter-exceptions to the interest barrier rule, e.g. for non-group companies.
There is currently a proceeding pending before the Federal Constitutional Court whether or not the interest barrier rule is in line with German constitutional law.
Germany operates a transfer pricing regime. As a matter of principle, transfer prices and any transaction between related parties have to be in line with the arm’s-length principle. There are several statutory rules to determine the transfer prices for products, services or the transfer of functions. According to these rules, the prevailing methods for determining transfer prices are the cost plus method, the comparable unrelated price method and the reselling method. In principle, the full range of the values calculated by the different methods can be applied.
Germany has strict rules with respect to the documentation of transfer prices. Violations of the documentation rules may lead to adverse consequences as the tax authorities are authorized to adjust transfer prices. Furthermore, there are penalties in case certain transfer pricing documentation requirements are not met.
(iii) a country-by-country reporting (if group consolidated revenues of at least EUR 750 Million).
Unilateral as well as multilateral advance pricing agreements are available in Germany.
Ireland does not have a thin capitalization regime.
Ireland has had transfer pricing rules since 2010. The transfer pricing rules must be interpreted in a manner consistent with the OECD transfer pricing guidelines. Somewhat unusually the Irish transfer pricing rules only apply to “trading” transactions that benefit from the 12.5% corporation tax rate. Ireland has a formal advance pricing agreement (“APA”) program. Only bilateral or multilateral APAs are possible. It is not possible to agree a unilateral APA with Irish Revenue.
The Mexican Income Tax Law provides several General Anti-Avoidance Rules, including thin cap rules, transfer pricing policies and CFC, to name a few.
The Mexican Income Tax Law establishes that income obtained by Mexican residents or foreign residents with a Mexican permanent establishment through foreign entities or vehicles in which they participate, directly or indirectly, is considered to be derived from a preferential tax regime or “Refipre” and must therefore be taxed according to the Refipre rules, if such income is (i) not subject to tax abroad or is subject to tax at a rate lower than 75% of the income tax that would have been due and payable in Mexico on such income, if it had been obtained directly by a Mexican resident, or (ii) earned through foreign legal vehicles or entities that are tax transparent abroad.
For such purposes, the Refipre rules take into account income obtained in cash, in kind, in services or in credit through foreign legal entities or vehicles and those which are presumptively determined by the Mexican tax authorities, even when such income has not been distributed to Mexican residents. In general, Mexican residents who obtain income from a Refipre must recognize it as taxable in Mexico during the year in which the income was derived, even if such income is not distributed to them by the foreign legal entity or vehicle that received it.
The Mexican Income Tax Law provides, as a general rule, that interest expenses incurred by Mexican entities are deductible on an accrual basis, subject to certain limitations amongst of which is that if interest expenses are paid to a non-resident related party, a 3 to 1 debt to equity ratio must be met; otherwise, any portion of the interest payments to foreign based related parties exceeding such ratio shall be non-deductible. This rule does allow for exceptions when it comes to debt contracted by taxpayers that are part of the Mexican financial system or that are engaged in the construction, operation or maintenance of productive infrastructure linked to the development of strategic sectors or electricity generation.
Transactions between related parties should comply with the arms’ length principle and be properly supported from a Mexican transfer pricing perspective (i.e., by a transfer pricing report), following the essential principles established under the OECD Transfer Pricing Guidelines.
Under current legislation, it is in fact possible for companies to obtain APAs with the tax authorities. These rulings may be effective in the fiscal year during which the relevant request was made, in the preceding fiscal year and up to the three fiscal years following the year in which the request was made.
The Norwegian CFC regime (No.: NOKUS) is applicable to Norwegian shareholders (i.e. shareholders, corporate or individual, resident in Norway for tax purposes) that directly or indirectly own at least 50 per cent of the shares or capital of a foreign company which is resident in a low-tax jurisdiction. For the purposes of these rules a jurisdiction is considered to be a low-tax jurisdiction if the effective taxation of the company is less than two thirds of what would be the effective taxation had the company been resident in Norway. It is not the headline tax rate but the effective tax rate which is relevant. The profits of the foreign company are attributed proportionally to the Norwegian shareholders irrespective of whether any distributions are actually made. A binding black list and a non-binding white list of jurisdictions with sufficient/insufficient taxation levels are issued by the Norwegian tax administration annually.
The CFC rules are not applicable to companies resident within the the European Economic Area (EEA), provided the company is genuinely established and actually performs economic activities. The analysis must be based on an overall assessment, and the Norwegian shareholder must provide evidence to the tax authorities that the substance requirement is met. In addition, if the company is not resident in a country with which Norway has entered into a tax treaty, which contains an information exchange clause, the company must present a statement from the tax authorities in its country of incorporation which confirms that the information provided is correct.
Further, the CFC rules are not applicable in situations where the company is resident in a country with which Norway has entered into a tax treaty for the avoidance of double taxation, and the company's income is not mainly of a passive nature.
Norwegian tax law contains no specific statutory or regulatory prescriptions on thin capitalisation but refers to the arm's length principle. All interest paid is, as a main rule, deductible. The tax authorities may contest the deductibility of interest paid to a parent company if the paying company is thinly capitalised. There is no general rule or safe harbour rule prescribing when the company is thinly capitalised or not. The assessment must be based on a number of factors such as the business sector of the company, the EBITDA of the company, and the debt-to-equity ratio of the company.
The interest deduction limitation rules state that interest expenses exceeding interest income (i.e. net interest expense) could be fully deducted if the total amount of net interest expense does not exceed NOK 5 mill. during the fiscal year, or if the interest is paid to a non-related party. Otherwise, net interest expense paid to a related party is deductible to the extent that internal and external interest expense combined does not exceed 25 per cent of the taxable EBITDA of the company. Parties are considered related in cases where one party has ownership or controls 50 per cent or more of the other party.
External loans guaranteed by a related party of the borrower (tainted debt) are also covered under the rule. The interest deduction limitation rule applies to limited liability companies, and other similar companies and entities. It also applies to partnerships, shareholders in CFCs and foreign companies with permanent establishments in Norway. Financial institutions are exempt from the interest deduction rule.
The Norwegian Ministry of Finance has proposed to extend the interest deduction limitation rules to include external debt, and a consultation procedure on the proposal was completed in 2017. The proposal was expected to be followed up in the national budget for 2018. However, the ministry has announced it still worked on the proposed amendments. The rules are expected to be introduced with effect for the income year of 2019.
Transfer pricing documentation rules impose an obligation for companies to prepare specific transfer pricing documentation as an attachment to their tax returns. Reporting requirements and transfer pricing documentation rules apply to companies that own or control, directly or indirectly, at least 50 % of another legal entity. A Norwegian permanent establishment with its head office in a foreign country, and a foreign permanent establishment with its head office in Norway, are covered by the rules. Furthermore, partnerships where one or more of the partners are taxable in Norway are also covered by the rules. The taxpayer must generally be prepared to file transfer pricing documentation (type and volume of the transactions, functional analysis, comparable analysis, and a report of the transfer pricing method used) within 45 days of a written notice from the tax authorities.
Norwegian tax authorities do not have a formal procedure to issue unilateral APAs. It is, however, possible to discuss the transfer pricing principles with the tax authorities. The Ministry of Finance has announced that they are considering introducing APA regulations, but they have not yet done so. In the case of sales of gas between related parties, a special APA procedure exists within the oil tax authorities, but so far this has not been used much in practice. Recently, Norway has opened up for mutual APA negotiations with other countries, but only a handful of pilot cases have so far been dealt with under such MAP/APA approach.
Controlled foreign corporation (CFC) rules may apply to Italian resident persons controlling non-resident companies, partnerships or other entities established in jurisdictions (other than EU Member States and EEA Member States) where the nominal tax rate is lower than 50 per cent of the Italian nominal tax rate. They may apply also in respect of companies, partnerships or other entities established outside the above jurisdictions if (i) the CFC is subject to a foreign effective tax rate lower than 50 per cent of the effective tax rate that would have applied if the CFC were resident of Italy, and (ii) the CFC realizes profits that qualify as passive income or profits from intra-group services for more than 50 per cent.
Italy repealed its thin cap regime as from tax year 2008. Italy applies an interest limitation regime whereby, in each tax year, companies can deduct interest expenses up to the amount of their interest income. The excess can be deducted for an amount equal to 30% of EBITDA of the relevant year. The excess 30% EBITDA as well as the interest expenses non-deductible in a given tax year can be carried forward and used or deducted in following tax years.
Italy applies transfer pricing legislation largely consistent with the OECD arm’s length standard. The legislation has been recently endorsed in order to reflect the latest changes to the OECD Transfer Pricing Guidelines and the tax authorities usually make reference to such Guidelines. As above indicated (see answer to question 1 above), a taxpayer may apply for a unilateral advance pricing agreement. If the other country involved in the cross border transactions signed a double tax treaty with Italy, the taxpayer can apply for a bilateral advance pricing agreement.
the annual total gross revenue of the foreign company in the related period in foreign currency exceeds the equivalent of TRY 100,000.
If these conditions are fulfilled, the profits of the CFC will be included in the corporate tax base of the controlling resident company, and it will be subject to taxation in Turkey without consideration of whether or not the profits are distributed.
The thin capitalization issue is covered in Article 12 of the CITL. According to this article, if the borrowings from shareholders or from persons related to shareholders exceeds three times the shareholders equity of the borrower company at any time within the relevant year, the excess portion of the borrowing will be considered to be thin capital. “Related parties” is defined as shareholders and persons who are related to the shareholders that own 10% or more of the shares, voting rights or rights to receive dividends of the company. The shareholders equity of the borrower company is defined as the total amount of the shareholders equity of the corporation at the beginning of the fiscal year, or the difference between the assets and liabilities of the company. If the company has negative shareholders equity at the beginning of the year, then any borrowings from related parties will be considered to be thin capital. If thin capitalization exists, the interest paid or accrued, foreign exchange losses and other similar expenses calculated for the loans that are considered to be thin capital are treated as non-deductible for CIT purposes. Moreover, the interest paid or accrued and similar payments on thin capital will be treated at the end of the relevant fiscal year as dividends and will be subject to withholding tax.
Specific transfer pricing rules are valid in Turkey as of 1 January 2007 under Article 13 of the CITL, entitled “Disguised Profit Distribution through Transfer Pricing”.
The regulations in Article 13 follow the arm’s-length principle established by the Organisation for Economic Co-operation and Development Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Guidelines), and are applicable to all financial, economic and commercial transactions and employment relations between related parties. Details on the application of Article 13 are provided in a communiqué regarding disguised profit distribution through transfer pricing.
Turkish transfer pricing (TP) legislation is part of the CITL. The arm’s-length principle, which is defined in line with OECD Guidelines and Article 9 of the OECD Model Tax Convention, is described in Article 13 of the CITL, along with a detailed definition of related parties and the introduction of methods to be applied to determine arm’s-length prices. According to the CITL, related parties must set transfer prices for the purchase and sale of goods and services equal to those they would have agreed to had they been unrelated parties. A comprehensive definition of what constitutes a related party is found in Article 13 of the CITL. The definition of related party in Turkish transfer pricing regulations is very broad, and it includes direct and indirect involvement in management or control, in addition to the existence of a shareholder/ownership relationship. In addition to transactions with foreign group companies, the scope of the law also includes transactions with entities that are based in tax havens or jurisdictions those are considered harmful tax regimes by the Turkish government.
Principles of transfer pricing documentation are covered in a TP communiqué. The communiqué introduced two different types of documentation liability for taxpayers. Accordingly, taxpayers need to fill out the form in the appendix of the corporate income tax return with information on the goods and services purchased and sales transactions they perform with their related parties in each accounting period. Furthermore, taxpayers registered with the Directorate of Major Taxpayers Tax Office are obliged to prepare an annual transfer pricing report including the information and documents stipulated by the communiqué and in the format defined in the same communiqué. These reports are completed to reflect the domestic and overseas transactions carried out with related parties in each accounting period and overseas transactions carried out in a given accounting period with other corporate income tax payers and their related parties. They need to be completed by the submission date of the corporate income tax return and to be submitted upon demand to the authority or officials authorized to carry out tax inspections after the end of these given periods.
The legislation requires documentation as part of the transfer pricing rules describing how Turkish taxpayers should keep documented evidence within the company in case of a request from the tax authorities. The documentation must show how the arm’s length price was determined and the methodology selected and applied using any fiscal records, calculations and charts available to the taxpayer.
An advance pricing agreement is a method used to determine the prices for purchases or sales of goods or services between related parties, and may be agreed upon with the Ministry of Finance upon a taxpayer request. This approved method will be fixed for a maximum period of three years within the terms and conditions of the agreement. If the administration finds the agreement interests more than one country, and if there are already APAs with another/other country/countries, the administration may consider a bilateral or multilateral agreement. In practice, the APA process changes according to the complexity and type (unilateral, bilateral or multilateral) of agreement, and the process cannot be completed in fewer than 18 to 24 months, on average.
A) As for the CFC rule, Japanese tax law has “anti-tax haven” rules, or a Japanese version of the CFC rules. These rules have been overhauled by the 2017 annual tax reform in response to the BEPS Action Plan 3, and applies to Japanese shareholders from the fiscal years of the CFC beginning on or after April 1, 2018.
If the Japanese CFC rules apply, the Japanese corporation that is a shareholder of the CFC will be taxed upon its pro rata share of certain adjusted income of the CFC (to be calculated based on the CFC’s total income and gains) . In general, Japanese CFC rules apply if (i) Japanese resident individuals and Japanese corporations collectively own directly or indirectly more than 50% of the total issued shares, voting rights or rights to receive dividends of a foreign corporation; (ii) a particular Japanese resident individual or a Japanese corporation (which is the subject taxpayer) owns directly or indirectly 10% or more of the total issued shares, voting rights or rights to receive dividends of that foreign corporation; and (iii) the effective income tax burden (rather than the face or nominal tax rate) of that foreign corporation in a given fiscal year is less than (i) 30% for certain shell-company CFCs and cash-box-company CFCs or (ii) 20% for all other CFCs. Typical examples include Cayman Islands, Hong Kong and Singapore subsidiaries of a Japanese corporation. It should be noted that tax-exempt income and gains in the foreign jurisdiction will lower the effective income tax burden; for example, if a Dutch subsidiary of a Japanese corporation is exempt from substantial amount of capital gains by the Dutch participation exemption, the effective income tax burden in that fiscal year could be less than 20%, despite the Dutch statutory corporate tax rate of 25%. That will make the Dutch subsidiary a CFC for that fiscal year. However, exemption of dividends received by the Dutch subsidiary from foreign companies by the participation exemption will not lower the effective income tax burden (this treatment is only limited to dividends).
Even if the Japanese CFC rules apply because all the conditions explained above are met, there is an active business income exemption. That is, if the CFC meets all of the following criteria, the Japanese CFC rules apply only to the extent of the CFC’s certain enumerated passive income (rather than the CFC’s total income including active income): (i) the principal business of the CFC is other than financial investments in shares, bonds or IPs or leasing of vessels, (ii) the CFC is managed and administered on its own within the jurisdiction of its incorporation, rather than from Japan, (iii) the CFC maintains physical fixed premises such as offices and factories within the jurisdiction of its incorporation that is necessary to do its business, and (iv) depending on the type of business, the CFC does business principally within the jurisdiction of its incorporation (e.g., manufacturing) or deals with unrelated third parties to account for 50% or more of the total business transactions (e.g., distribution, transportation). If all these elements are met, the CFC’s income to be aggregated with the Japanese shareholder’s income will be limited to passive income, such as (a) dividends and capital gains from shares (but excluding those where the shareholding ratio is 25% or more for at least 6 months), (b) interest on deposits, bonds and loans (excluding interest from certain qualifying group-financing), (c) income from derivatives (excluding certain qualifying hedges), (d) foreign exchange gains (excluding those arising in the ordinary course of business), (e) royalties and disposition gains from IPs (excluding those where the IP is developed on its own) and (f) leasing income from real properties and fixed properties (excluding real properties located and fixed properties used in the jurisdiction of incorporation of the CFC).
The active business income exemption has been expanded to a certain qualifying regional headquarters or intermediate holding company; that is, if a foreign subsidiary incorporated in the Asian-hub low-tax countries such as Singapore and Hong Kong operates as an Asian regional headquarters or as an intermediate holding company for the Japanese parent corporation, subject to certain requirements being met, the CFC will not be disqualified from meeting the condition (i) above (i.e., the principal business of the CFC is other than financial investments in shares), merely because it is a holding company.
If the debt giving rise to the interest is owed to a foreign corporation, which is a controlling shareholder (owning directly or indirectly 50% or more of the total shares) of the Japanese corporation, the ‘thin capitalization’ rules apply, and, generally speaking, interest payable upon the portion of the debt exceeding three times the shareholders’ equity of the Japanese corporation will be nondeductible. The ‘thin capitalization’ rules apply not only in the case of direct financing by the controlling shareholder, but also in other similar cases, such as financing by third parties with a guarantee provided by the controlling shareholder.
Transfer pricing rules also apply to interest payable to affiliated foreign corporations of the Japanese corporation in order to require that the interest rate be arm’s length (i.e., the portion of the interest exceeding the arm’s-length rate will be denied deduction). One Japanese court precedent indicates that the arm’s-length interest rate generally refers to the rate available in the market for substantially similar finance transactions.
Further, as a result of the 2012 annual tax reform, a Japanese version of the ‘earnings stripping’ rules has been introduced, and applies from fiscal years beginning on or after April 1, 2013. There, if the ‘net’ amount of the interest paid to certain foreign related parties of the Japanese corporation in a fiscal year exceeds 50% of certain ‘adjusted income’ (substantially equal to EBITDA, i.e., taxable income before that interest deduction, depreciation, etc.) of that Japanese corporation in that fiscal year (i.e., interest paid to foreign affiliates is excessive as compared to the taxable income), the excess portion of the interest will not be deductible in that fiscal year. The excess portion will be carried forward for seven future fiscal years, however, and will be deductible to the extent the above conditions are met in the relevant future fiscal year. There is a certain de minimis exception, as well as an exception where the gross amount of interest paid to foreign related parties does not exceed 50% of the total gross amount of interest (including interest paid to third parties). The Japanese government is now reviewing whether these earnings stripping rules should be more tightened, in response to the BEPS Action Plan 4, by lowering the threshold percentage rate from 50% to some 10-30%.
It should be noted that interest deduction can be denied, even if none of the foregoing regimes is applicable, if the Japanese tax authority considers the relevant debt transaction as avoiding Japanese tax and invokes the anti-avoidance statute applicable to closely-held corporations in the corporation tax law. The Universal Music case mentioned above is an example.
C) As to the transfer pricing regime, generally, the Japanese government is of the position that Japanese transfer pricing rules as well as enforcement thereof should closely follow the OECD standards. For example, Japanese transfer pricing rules repealed priority of the three basic methods (CUP, RP and CP) over other methods (PS and TNMM), and adopted the “best method” rule. In addition, it has been made clear that the concept of a “range” of arm’s length profit level can be used for Japanese transfer pricing purposes (provided that it means a “full range” predicated upon full comparability, rather than the statistical approach of interquartile range) for the purpose of issuing a transfer pricing assessment. In addition, as a matter of enforcement or transfer pricing audit, it is very common that taxpayers make defensive arguments by referring to the OECD Guidelines along with Japanese local laws and regulations, and the Japanese tax authority generally accepts such arguments as legitimate. Indeed, some tax treaties, e.g., that with the United States, expressly provide that transfer pricing enforcement shall be made in accordance with the OECD Guidelines.
It is possible to obtain an advance pricing arrangement (APA) from the tax authority, and it is a very common practice. In an APA, there generally is even more flexibility as compared to transfer pricing audit; e.g., the statistical approach of interquartile range is very commonly used and accepted. However, as an APA requires substantial time, cost and burden to deal with the tax authority (e.g., for responding to information and document requests), taxpayers generally concentrate on intra-group transactions that have significant volume and a large amount of tax at stake in applying for an APA. It is not rare that an APA takes two or three years until concluded.
There are no CFC rules in Gibraltar. However, under the general anti-avoidance provision in our Tax Act, the Commissioner may disregard any CFC or transaction with such CFC where the Commissioner believes that it is fictitious or artificial.
Interest paid on a loan by a company to related parties (which are not themselves a company) or loans where security is provided by related parties, where the ratio of the value of the loan capital to the equity of the company exceeds 5 to 1 is considered as a dividend payment and thus not a deductible expense for tax purposes.
The amount of interest payments to connected persons which is in excess of that payable at “arm’s length” is deemed to be a dividend.
(iii)	75% of the pre expenses profit.
The UK CFC regime is based on rules designed to prevent diversion of UK profits to low tax territories. Where UK profits are diverted to a CFC, those profits are apportioned and charged on a UK corporate interest-holder that holds at least a 25% interest in the CFC. There are a number of exemptions to reflect the fact that the majority of CFCs are established for genuine commercial reasons. The Finance Act 2004 abolished the separate thin capitalization requirements that had existed previously and subsumed them within the general transfer pricing rules in the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010).
The UK transfer pricing (TP) regime is contained in Parts 4 and 5 of Taxation (International and Other Provisions) Act 2010. The UK TP regime must be considered in light of the recently implemented Diverted Profits Tax (DPT) rules, which were introduced by the Finance Act 2015. There is also an advanced pricing agreement (APA) programme through which unilateral, bilateral and multilateral APAs can be obtained. The process by which such an agreement can be obtained is detailed in HMRC’s Statement of Practice 2/2010. HMRC will determine the taxpayer’s DPT position before agreeing to an APA.
As a result of the Starbucks and Apple decisions, any business which has secured a favourable APA could, potentially, be at risk of having those arrangements reviewed under the State Aid rules and be faced with having to make significant payments to repay tax benefits received under APAs that, allegedly, do not comply with State Aid rules.

tokenized:
Switzerland does not have a CFC regime . However , according to the case law of the Swiss Federal Supreme Court , companies with statutory seats located abroad , but who have little or no local substance and are effectively managed in Switzerland may be subject to Swiss income tax .
 For finance companies , the maximum debt allowed is 6/7 of their total assets .
 In addition , the FTA publishes annually safe harbour interest rates for loans granted to related parties .
 Interest paid on debt exceeding the maximum debt allowed and interest rates exceeding the safe harbour interest rates are requalified as a hidden dividend if paid to a shareholder or a related party . Consequently , such interest is not a deductible expense for federal and cantonal income tax purposes and is subject to withholding tax at a rate of 35 % ( which may be reduced under a relevant tax treaty ) .
 However , the rules set out above are merely safe harbour rules and allow the taxpayer to prove that different arm ’s length debt - to - equity ratio and interest rates apply .
 Swiss codified tax law contains very few rules relating to transfer pricing questions . As a general rule , Swiss law states that ( i ) expenses of a company must be commercially justified and ( ii ) profits not shown in the profit and loss statement of a company must still be included in its taxable profit .
 Based on these general rules , Swiss tax authorities can correct intra - group transactions that are not at arm ’s length . In determining whether an intra - group transaction is at arm ’s length or not , the Swiss administrative practice generally follows the OECD transfer pricing guidelines .
 As previously mentioned , the FTA publishes yearly rules regarding safe harbour interest rates for loans and advances between related parties , in various currencies . This publication provides for maximum rates regarding loans from the shareholders or related parties to the company , and minimum rates regarding loans from the company to shareholders or related parties .
 It is possible to obtain an advance pricing agreement ( ‘ APA ’ ) with the Swiss tax authorities . In general , the cantonal tax authorities are competent for granting unilateral APAs , whereas bi- or multilateral APAs , as well as unilateral APAs regarding Swiss withholding tax , are negotiated with the involvement of the FTA .
 The US has comprehensive CFC rules , which have been further expanded by TCJA to include a global minimum tax of 10.5 % on most CFC profits of a US corporate shareholder .
 Under longstanding CFC rules , a controlling US shareholder of a CFC is subject to current US taxation on any so - called Subpart F income of the CFC . Subpart F income is intended to capture what Congress perceived to be “ tax haven ” income , and thus includes certain interest , dividends , rents , royalties and gains , as well as certain income from sale of property and provision of services involving related parties . An exception to subpart F income is provided for income subject to a local country tax of at least 90 % of US the corporate rate ( now 18.9 % = 90 % * 21 % ) .
 In addition , the TCJA introduced a new category of income captured by the CFC regime – so - called “ Global Intangible Low - Taxed Income ” ( GILTI ) . GILTI consists of all income of the shareholders ’ CFCs that is not subpart F income ( or eligible for certain limited exceptions ) , to the extent that such income exceeds a 10 % return on the CFC ’s investment in tangible assets used in its trade or business ( measured by tax basis ) . GILTI is fully included in taxable income of the US shareholder on a current basis in each year , with a 50 % deduction provided for US corporate shareholders that results in an effective US tax rate of 10.5 % . Foreign tax credits are allowed against US tax on both subpart F income and GILTI .
 The TCJA also added the US ’s first comprehensive thin capitalization test through amended Code Section 163(j ) . As amended Section 163(j ) limits interest deductions of corporations and other businesses to 30 % of adjusted taxable income . New Code Section 163(j ) applies to all debt , whether third party or intercompany , whether the lender is US or foreign , and regardless of the US corporation ’s debt - equity ratio . “ Adjusted taxable income ” is defined generally as US taxable income without regard to interest expense , loss carryforwards , and for taxable years beginning before January 1 , 2022 , depreciation or amortization ( i.e. , EBITDA ) . After 2022 , deductions for depreciation or amortization are no longer added back , so that interest expense is limited to 30 % of EBIT . Interest expense deductions that are disallowed carry forward indefinitely .
 As noted above , Code Section 482 and the regulations thereunder provide a comprehensive set of transfer pricing rules . In addition , strict liability penalties apply to transfer pricing adjustments in excess of certain thresholds , unless the taxpayers has maintained contemporaneous documentation with the filing of the original tax return in a form specified by the transfer pricing regulations .
 Advanced Pricing Agreements ( APAs ) are available from the IRS on a prospective basis . In the case of transactions between the US Company and an affiliate in a treaty country , bi - lateral and multi - lateral APAs are also available involving the IRS and the other competent authorities .
 The FTC provides for a CFC rule that constitutes an exception to the territoriality principle : only profits derived from activities carried out in France are taxable in France . According to this rule , profits realised by an entity , which is , directly or indirectly , more than 50 % , owned by a French company and which is located in a privileged tax regime country , are deemed to be received by the French company in due proportion of the shares owned and therefore , are to be taxed in France . An entity is considered to be located in a privileged tax regime country if the effective corporate tax rate applied in this country is at least 50 % lower than France ’s .
 the amount of interest paid to related parties exceeds the amount of interest received from related parties .
 The portion of interest paid which exceeds the highest of the three set criteria is not deductible . These rules can be extended to interest borne with respect to a bank loan when certain guarantees have been granted by affiliated companies to the lender .
 Anti - hybrid stipulation , which forbids the deduction of interests , if the creditor is not taxable , at least at 8.33 % ( i.e. 25 % of the French CIT ) on the financial proceeds .
 The FTA applies the arm ’s length principle : prices applied to transactions between related parties must be similar to prices that would have been agreed upon for transactions between independent companies . If not , the FTA may presume an indirect transfer of profits from the French company to its foreign affiliate and reassess its taxable income accordingly , that is to the extent of the amount deemed to have been unduly shifted . The burden of proof regarding an indirect transfer of profits lies with the tax authorities .
 The rules aiming at limiting the deductibility of the interest should be deeply amended by the 2019 Finance Bill in order to transpose the Anti Avoidance Directive ( ' ATAD ' ) into the French interest limitation regime . The Finance bill should limit the deduction of net financial charges ( including debts subscribed with a Bank or a third party ) to either 30 % of the entity 's EBITDA or 3 million euros ( if higher ) with a calculation made at the group level . The " rabot " would be removed and the thin - capitalization rules would be deeply amended .
 The FTC provides for the possibility of a bilateral advance pricing agreement between multinational companies and the tax authorities which would aim at fixing the transfer pricing method to be used in cross - border transactions .
 The State Aid action has not dramatically changed the situation , but just increased the already thorough examination of the APA requests .
 Interest paid to related parties located in a tax haven or privileged tax regime jurisdictions is deductible provided that the expenses are necessary and the debt with such related party does not exceed 30 % of the Brazilian company ’s equity .
 Additionally , Brazil does also provide for CFC rules , which in general , impose taxation on undistributed profits from foreign controlled and affiliated companies . Accordingly , profits from foreign controlled companies should be considered deemed distributed to the Brazilian controlling company by December 31 of each calendar year . On the other hand , provided that some conditions are met , profits derived from foreign affiliates not located in tax haven or privileged tax regimes jurisdictions are only subject to taxation in Brazil when they are effectively distributed .
 Moreover , Brazilian transfer pricing rules were enacted by Law 9,430/96 and its subsequent amendments . Such rules introduced transfer pricing controls , in order to avoid undervaluation of export prices , or overvaluation of import prices , for purposes of calculating corporate income taxes ( Income tax – “ IRPJ ” - and Social Contribution on Profits Tax – “ CSLL ” ) . Transfer pricing rules are applicable to any import or export of goods , services and rights , performed between a Brazilian company and a related party abroad , or a party located in a tax haven or privileged tax jurisdiction .
 There are five methods to calculate import transfer price , as well as there are four methods to calculate export transfer price . For import transactions , if the actual import price is higher than the calculated transfer price , the taxpayer can not deduct the difference for purposes of IRPJ and CSLL . For export transactions , if the actual price is lower than the applicable transfer price , the difference shall be computed for IRPJ and CSLL purposes .
 It is worth mentioning that the Brazilian transfer pricing rules differ from the OECD Guidelines related to the referred subject . Accordingly , Brazilian rules adopt fixed margins to calculate the transfer price , instead of the arm ’s length principles .
 Finally , please note that the transfer pricing rules do also apply to loan transactions between foreign related parties .
 ( iii ) the income of the controlled foreign corporation is low - taxed , which means that the tax levied is below 25 % .
 However , the German CFC rules provide for an exemption for corporations which have their statutory seat or their place of effective management within the EU or EEA . Such corporations may prove that their business has economic substance , they exercises genuine commercial activities and adhere to the arm’s - length - principle . In that case , the EU / EEA corporations will not be deemed to constitute a controlled foreign corporation under the German CFC rules .
 Germany operates a thin - capitalization regime , the so - called interest barrier rule . Generally , the interest barrier rule is applicable if the annual net interest expenses amounts to or exceeds EUR 3 Million . Under the interest barrier rule , the tax deductibility of interest expense on any debt of a company is restricted to the amount of the interest income plus 30 % of the company ’s EBITDA for tax purposes . The taxable EBITDA differs from the financial EBITDA because it is based on the taxable income of the company only . Therefore , any tax free income is not part of the taxable EBITDA . There are various exceptions and counter - exceptions to the interest barrier rule , e.g. for non - group companies .
 There is currently a proceeding pending before the Federal Constitutional Court whether or not the interest barrier rule is in line with German constitutional law .
 Germany operates a transfer pricing regime . As a matter of principle , transfer prices and any transaction between related parties have to be in line with the arm’s - length principle . There are several statutory rules to determine the transfer prices for products , services or the transfer of functions . According to these rules , the prevailing methods for determining transfer prices are the cost plus method , the comparable unrelated price method and the reselling method . In principle , the full range of the values calculated by the different methods can be applied .
 Germany has strict rules with respect to the documentation of transfer prices . Violations of the documentation rules may lead to adverse consequences as the tax authorities are authorized to adjust transfer prices . Furthermore , there are penalties in case certain transfer pricing documentation requirements are not met .
 ( iii ) a country - by - country reporting ( if group consolidated revenues of at least EUR 750 Million ) .
 Unilateral as well as multilateral advance pricing agreements are available in Germany .
 Ireland does not have a thin capitalization regime .
 Ireland has had transfer pricing rules since 2010 . The transfer pricing rules must be interpreted in a manner consistent with the OECD transfer pricing guidelines . Somewhat unusually the Irish transfer pricing rules only apply to “ trading ” transactions that benefit from the 12.5 % corporation tax rate . Ireland has a formal advance pricing agreement ( “ APA ” ) program . Only bilateral or multilateral APAs are possible . It is not possible to agree a unilateral APA with Irish Revenue .
 The Mexican Income Tax Law provides several General Anti - Avoidance Rules , including thin cap rules , transfer pricing policies and CFC , to name a few .
 The Mexican Income Tax Law establishes that income obtained by Mexican residents or foreign residents with a Mexican permanent establishment through foreign entities or vehicles in which they participate , directly or indirectly , is considered to be derived from a preferential tax regime or “ Refipre ” and must therefore be taxed according to the Refipre rules , if such income is ( i ) not subject to tax abroad or is subject to tax at a rate lower than 75 % of the income tax that would have been due and payable in Mexico on such income , if it had been obtained directly by a Mexican resident , or ( ii ) earned through foreign legal vehicles or entities that are tax transparent abroad .
 For such purposes , the Refipre rules take into account income obtained in cash , in kind , in services or in credit through foreign legal entities or vehicles and those which are presumptively determined by the Mexican tax authorities , even when such income has not been distributed to Mexican residents . In general , Mexican residents who obtain income from a Refipre must recognize it as taxable in Mexico during the year in which the income was derived , even if such income is not distributed to them by the foreign legal entity or vehicle that received it .
 The Mexican Income Tax Law provides , as a general rule , that interest expenses incurred by Mexican entities are deductible on an accrual basis , subject to certain limitations amongst of which is that if interest expenses are paid to a non - resident related party , a 3 to 1 debt to equity ratio must be met ; otherwise , any portion of the interest payments to foreign based related parties exceeding such ratio shall be non - deductible . This rule does allow for exceptions when it comes to debt contracted by taxpayers that are part of the Mexican financial system or that are engaged in the construction , operation or maintenance of productive infrastructure linked to the development of strategic sectors or electricity generation .
 Transactions between related parties should comply with the arms ’ length principle and be properly supported from a Mexican transfer pricing perspective ( i.e. , by a transfer pricing report ) , following the essential principles established under the OECD Transfer Pricing Guidelines .
 Under current legislation , it is in fact possible for companies to obtain APAs with the tax authorities . These rulings may be effective in the fiscal year during which the relevant request was made , in the preceding fiscal year and up to the three fiscal years following the year in which the request was made .
 The Norwegian CFC regime ( No . : NOKUS ) is applicable to Norwegian shareholders ( i.e. shareholders , corporate or individual , resident in Norway for tax purposes ) that directly or indirectly own at least 50 per cent of the shares or capital of a foreign company which is resident in a low - tax jurisdiction . For the purposes of these rules a jurisdiction is considered to be a low - tax jurisdiction if the effective taxation of the company is less than two thirds of what would be the effective taxation had the company been resident in Norway . It is not the headline tax rate but the effective tax rate which is relevant . The profits of the foreign company are attributed proportionally to the Norwegian shareholders irrespective of whether any distributions are actually made . A binding black list and a non - binding white list of jurisdictions with sufficient / insufficient taxation levels are issued by the Norwegian tax administration annually .
 The CFC rules are not applicable to companies resident within the the European Economic Area ( EEA ) , provided the company is genuinely established and actually performs economic activities . The analysis must be based on an overall assessment , and the Norwegian shareholder must provide evidence to the tax authorities that the substance requirement is met . In addition , if the company is not resident in a country with which Norway has entered into a tax treaty , which contains an information exchange clause , the company must present a statement from the tax authorities in its country of incorporation which confirms that the information provided is correct .
 Further , the CFC rules are not applicable in situations where the company is resident in a country with which Norway has entered into a tax treaty for the avoidance of double taxation , and the company 's income is not mainly of a passive nature .
 Norwegian tax law contains no specific statutory or regulatory prescriptions on thin capitalisation but refers to the arm 's length principle . All interest paid is , as a main rule , deductible . The tax authorities may contest the deductibility of interest paid to a parent company if the paying company is thinly capitalised . There is no general rule or safe harbour rule prescribing when the company is thinly capitalised or not . The assessment must be based on a number of factors such as the business sector of the company , the EBITDA of the company , and the debt - to - equity ratio of the company .
 The interest deduction limitation rules state that interest expenses exceeding interest income ( i.e. net interest expense ) could be fully deducted if the total amount of net interest expense does not exceed NOK 5 mill . during the fiscal year , or if the interest is paid to a non - related party . Otherwise , net interest expense paid to a related party is deductible to the extent that internal and external interest expense combined does not exceed 25 per cent of the taxable EBITDA of the company . Parties are considered related in cases where one party has ownership or controls 50 per cent or more of the other party .
 External loans guaranteed by a related party of the borrower ( tainted debt ) are also covered under the rule . The interest deduction limitation rule applies to limited liability companies , and other similar companies and entities . It also applies to partnerships , shareholders in CFCs and foreign companies with permanent establishments in Norway . Financial institutions are exempt from the interest deduction rule .
 The Norwegian Ministry of Finance has proposed to extend the interest deduction limitation rules to include external debt , and a consultation procedure on the proposal was completed in 2017 . The proposal was expected to be followed up in the national budget for 2018 . However , the ministry has announced it still worked on the proposed amendments . The rules are expected to be introduced with effect for the income year of 2019 .
 Transfer pricing documentation rules impose an obligation for companies to prepare specific transfer pricing documentation as an attachment to their tax returns . Reporting requirements and transfer pricing documentation rules apply to companies that own or control , directly or indirectly , at least 50 % of another legal entity . A Norwegian permanent establishment with its head office in a foreign country , and a foreign permanent establishment with its head office in Norway , are covered by the rules . Furthermore , partnerships where one or more of the partners are taxable in Norway are also covered by the rules . The taxpayer must generally be prepared to file transfer pricing documentation ( type and volume of the transactions , functional analysis , comparable analysis , and a report of the transfer pricing method used ) within 45 days of a written notice from the tax authorities .
 Norwegian tax authorities do not have a formal procedure to issue unilateral APAs . It is , however , possible to discuss the transfer pricing principles with the tax authorities . The Ministry of Finance has announced that they are considering introducing APA regulations , but they have not yet done so . In the case of sales of gas between related parties , a special APA procedure exists within the oil tax authorities , but so far this has not been used much in practice . Recently , Norway has opened up for mutual APA negotiations with other countries , but only a handful of pilot cases have so far been dealt with under such MAP / APA approach .
 Controlled foreign corporation ( CFC ) rules may apply to Italian resident persons controlling non - resident companies , partnerships or other entities established in jurisdictions ( other than EU Member States and EEA Member States ) where the nominal tax rate is lower than 50 per cent of the Italian nominal tax rate . They may apply also in respect of companies , partnerships or other entities established outside the above jurisdictions if ( i ) the CFC is subject to a foreign effective tax rate lower than 50 per cent of the effective tax rate that would have applied if the CFC were resident of Italy , and ( ii ) the CFC realizes profits that qualify as passive income or profits from intra - group services for more than 50 per cent .
 Italy repealed its thin cap regime as from tax year 2008 . Italy applies an interest limitation regime whereby , in each tax year , companies can deduct interest expenses up to the amount of their interest income . The excess can be deducted for an amount equal to 30 % of EBITDA of the relevant year . The excess 30 % EBITDA as well as the interest expenses non - deductible in a given tax year can be carried forward and used or deducted in following tax years .
 Italy applies transfer pricing legislation largely consistent with the OECD arm ’s length standard . The legislation has been recently endorsed in order to reflect the latest changes to the OECD Transfer Pricing Guidelines and the tax authorities usually make reference to such Guidelines . As above indicated ( see answer to question 1 above ) , a taxpayer may apply for a unilateral advance pricing agreement . If the other country involved in the cross border transactions signed a double tax treaty with Italy , the taxpayer can apply for a bilateral advance pricing agreement .
 the annual total gross revenue of the foreign company in the related period in foreign currency exceeds the equivalent of TRY 100,000 .
 If these conditions are fulfilled , the profits of the CFC will be included in the corporate tax base of the controlling resident company , and it will be subject to taxation in Turkey without consideration of whether or not the profits are distributed .
 The thin capitalization issue is covered in Article 12 of the CITL . According to this article , if the borrowings from shareholders or from persons related to shareholders exceeds three times the shareholders equity of the borrower company at any time within the relevant year , the excess portion of the borrowing will be considered to be thin capital . “ Related parties ” is defined as shareholders and persons who are related to the shareholders that own 10 % or more of the shares , voting rights or rights to receive dividends of the company . The shareholders equity of the borrower company is defined as the total amount of the shareholders equity of the corporation at the beginning of the fiscal year , or the difference between the assets and liabilities of the company . If the company has negative shareholders equity at the beginning of the year , then any borrowings from related parties will be considered to be thin capital . If thin capitalization exists , the interest paid or accrued , foreign exchange losses and other similar expenses calculated for the loans that are considered to be thin capital are treated as non - deductible for CIT purposes . Moreover , the interest paid or accrued and similar payments on thin capital will be treated at the end of the relevant fiscal year as dividends and will be subject to withholding tax .
 Specific transfer pricing rules are valid in Turkey as of 1 January 2007 under Article 13 of the CITL , entitled “ Disguised Profit Distribution through Transfer Pricing ” .
 The regulations in Article 13 follow the arm’s - length principle established by the Organisation for Economic Co - operation and Development Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ( OECD Guidelines ) , and are applicable to all financial , economic and commercial transactions and employment relations between related parties . Details on the application of Article 13 are provided in a communiqué regarding disguised profit distribution through transfer pricing .
 Turkish transfer pricing ( TP ) legislation is part of the CITL . The arm’s - length principle , which is defined in line with OECD Guidelines and Article 9 of the OECD Model Tax Convention , is described in Article 13 of the CITL , along with a detailed definition of related parties and the introduction of methods to be applied to determine arm’s - length prices . According to the CITL , related parties must set transfer prices for the purchase and sale of goods and services equal to those they would have agreed to had they been unrelated parties . A comprehensive definition of what constitutes a related party is found in Article 13 of the CITL . The definition of related party in Turkish transfer pricing regulations is very broad , and it includes direct and indirect involvement in management or control , in addition to the existence of a shareholder / ownership relationship . In addition to transactions with foreign group companies , the scope of the law also includes transactions with entities that are based in tax havens or jurisdictions those are considered harmful tax regimes by the Turkish government .
 Principles of transfer pricing documentation are covered in a TP communiqué . The communiqué introduced two different types of documentation liability for taxpayers . Accordingly , taxpayers need to fill out the form in the appendix of the corporate income tax return with information on the goods and services purchased and sales transactions they perform with their related parties in each accounting period . Furthermore , taxpayers registered with the Directorate of Major Taxpayers Tax Office are obliged to prepare an annual transfer pricing report including the information and documents stipulated by the communiqué and in the format defined in the same communiqué . These reports are completed to reflect the domestic and overseas transactions carried out with related parties in each accounting period and overseas transactions carried out in a given accounting period with other corporate income tax payers and their related parties . They need to be completed by the submission date of the corporate income tax return and to be submitted upon demand to the authority or officials authorized to carry out tax inspections after the end of these given periods .
 The legislation requires documentation as part of the transfer pricing rules describing how Turkish taxpayers should keep documented evidence within the company in case of a request from the tax authorities . The documentation must show how the arm ’s length price was determined and the methodology selected and applied using any fiscal records , calculations and charts available to the taxpayer .
 An advance pricing agreement is a method used to determine the prices for purchases or sales of goods or services between related parties , and may be agreed upon with the Ministry of Finance upon a taxpayer request . This approved method will be fixed for a maximum period of three years within the terms and conditions of the agreement . If the administration finds the agreement interests more than one country , and if there are already APAs with another / other country / countries , the administration may consider a bilateral or multilateral agreement . In practice , the APA process changes according to the complexity and type ( unilateral , bilateral or multilateral ) of agreement , and the process can not be completed in fewer than 18 to 24 months , on average .
 A ) As for the CFC rule , Japanese tax law has “ anti - tax haven ” rules , or a Japanese version of the CFC rules . These rules have been overhauled by the 2017 annual tax reform in response to the BEPS Action Plan 3 , and applies to Japanese shareholders from the fiscal years of the CFC beginning on or after April 1 , 2018 .
 If the Japanese CFC rules apply , the Japanese corporation that is a shareholder of the CFC will be taxed upon its pro rata share of certain adjusted income of the CFC ( to be calculated based on the CFC ’s total income and gains ) . In general , Japanese CFC rules apply if ( i ) Japanese resident individuals and Japanese corporations collectively own directly or indirectly more than 50 % of the total issued shares , voting rights or rights to receive dividends of a foreign corporation ; ( ii ) a particular Japanese resident individual or a Japanese corporation ( which is the subject taxpayer ) owns directly or indirectly 10 % or more of the total issued shares , voting rights or rights to receive dividends of that foreign corporation ; and ( iii ) the effective income tax burden ( rather than the face or nominal tax rate ) of that foreign corporation in a given fiscal year is less than ( i ) 30 % for certain shell - company CFCs and cash - box - company CFCs or ( ii ) 20 % for all other CFCs . Typical examples include Cayman Islands , Hong Kong and Singapore subsidiaries of a Japanese corporation . It should be noted that tax - exempt income and gains in the foreign jurisdiction will lower the effective income tax burden ; for example , if a Dutch subsidiary of a Japanese corporation is exempt from substantial amount of capital gains by the Dutch participation exemption , the effective income tax burden in that fiscal year could be less than 20 % , despite the Dutch statutory corporate tax rate of 25 % . That will make the Dutch subsidiary a CFC for that fiscal year . However , exemption of dividends received by the Dutch subsidiary from foreign companies by the participation exemption will not lower the effective income tax burden ( this treatment is only limited to dividends ) .
 Even if the Japanese CFC rules apply because all the conditions explained above are met , there is an active business income exemption . That is , if the CFC meets all of the following criteria , the Japanese CFC rules apply only to the extent of the CFC ’s certain enumerated passive income ( rather than the CFC ’s total income including active income ): ( i ) the principal business of the CFC is other than financial investments in shares , bonds or IPs or leasing of vessels , ( ii ) the CFC is managed and administered on its own within the jurisdiction of its incorporation , rather than from Japan , ( iii ) the CFC maintains physical fixed premises such as offices and factories within the jurisdiction of its incorporation that is necessary to do its business , and ( iv ) depending on the type of business , the CFC does business principally within the jurisdiction of its incorporation ( e.g. , manufacturing ) or deals with unrelated third parties to account for 50 % or more of the total business transactions ( e.g. , distribution , transportation ) . If all these elements are met , the CFC ’s income to be aggregated with the Japanese shareholder ’s income will be limited to passive income , such as ( a ) dividends and capital gains from shares ( but excluding those where the shareholding ratio is 25 % or more for at least 6 months ) , ( b ) interest on deposits , bonds and loans ( excluding interest from certain qualifying group - financing ) , ( c ) income from derivatives ( excluding certain qualifying hedges ) , ( d ) foreign exchange gains ( excluding those arising in the ordinary course of business ) , ( e ) royalties and disposition gains from IPs ( excluding those where the IP is developed on its own ) and ( f ) leasing income from real properties and fixed properties ( excluding real properties located and fixed properties used in the jurisdiction of incorporation of the CFC ) .
 The active business income exemption has been expanded to a certain qualifying regional headquarters or intermediate holding company ; that is , if a foreign subsidiary incorporated in the Asian - hub low - tax countries such as Singapore and Hong Kong operates as an Asian regional headquarters or as an intermediate holding company for the Japanese parent corporation , subject to certain requirements being met , the CFC will not be disqualified from meeting the condition ( i ) above ( i.e. , the principal business of the CFC is other than financial investments in shares ) , merely because it is a holding company .
 If the debt giving rise to the interest is owed to a foreign corporation , which is a controlling shareholder ( owning directly or indirectly 50 % or more of the total shares ) of the Japanese corporation , the ‘ thin capitalization ’ rules apply , and , generally speaking , interest payable upon the portion of the debt exceeding three times the shareholders ’ equity of the Japanese corporation will be nondeductible . The ‘ thin capitalization ’ rules apply not only in the case of direct financing by the controlling shareholder , but also in other similar cases , such as financing by third parties with a guarantee provided by the controlling shareholder .
 Transfer pricing rules also apply to interest payable to affiliated foreign corporations of the Japanese corporation in order to require that the interest rate be arm ’s length ( i.e. , the portion of the interest exceeding the arm’s - length rate will be denied deduction ) . One Japanese court precedent indicates that the arm’s - length interest rate generally refers to the rate available in the market for substantially similar finance transactions .
 Further , as a result of the 2012 annual tax reform , a Japanese version of the ‘ earnings stripping ’ rules has been introduced , and applies from fiscal years beginning on or after April 1 , 2013 . There , if the ‘ net ’ amount of the interest paid to certain foreign related parties of the Japanese corporation in a fiscal year exceeds 50 % of certain ‘ adjusted income ’ ( substantially equal to EBITDA , i.e. , taxable income before that interest deduction , depreciation , etc . ) of that Japanese corporation in that fiscal year ( i.e. , interest paid to foreign affiliates is excessive as compared to the taxable income ) , the excess portion of the interest will not be deductible in that fiscal year . The excess portion will be carried forward for seven future fiscal years , however , and will be deductible to the extent the above conditions are met in the relevant future fiscal year . There is a certain de minimis exception , as well as an exception where the gross amount of interest paid to foreign related parties does not exceed 50 % of the total gross amount of interest ( including interest paid to third parties ) . The Japanese government is now reviewing whether these earnings stripping rules should be more tightened , in response to the BEPS Action Plan 4 , by lowering the threshold percentage rate from 50 % to some 10 - 30 % .
 It should be noted that interest deduction can be denied , even if none of the foregoing regimes is applicable , if the Japanese tax authority considers the relevant debt transaction as avoiding Japanese tax and invokes the anti - avoidance statute applicable to closely - held corporations in the corporation tax law . The Universal Music case mentioned above is an example .
 C ) As to the transfer pricing regime , generally , the Japanese government is of the position that Japanese transfer pricing rules as well as enforcement thereof should closely follow the OECD standards . For example , Japanese transfer pricing rules repealed priority of the three basic methods ( CUP , RP and CP ) over other methods ( PS and TNMM ) , and adopted the “ best method ” rule . In addition , it has been made clear that the concept of a “ range ” of arm ’s length profit level can be used for Japanese transfer pricing purposes ( provided that it means a “ full range ” predicated upon full comparability , rather than the statistical approach of interquartile range ) for the purpose of issuing a transfer pricing assessment . In addition , as a matter of enforcement or transfer pricing audit , it is very common that taxpayers make defensive arguments by referring to the OECD Guidelines along with Japanese local laws and regulations , and the Japanese tax authority generally accepts such arguments as legitimate . Indeed , some tax treaties , e.g. , that with the United States , expressly provide that transfer pricing enforcement shall be made in accordance with the OECD Guidelines .
 It is possible to obtain an advance pricing arrangement ( APA ) from the tax authority , and it is a very common practice . In an APA , there generally is even more flexibility as compared to transfer pricing audit ; e.g. , the statistical approach of interquartile range is very commonly used and accepted . However , as an APA requires substantial time , cost and burden to deal with the tax authority ( e.g. , for responding to information and document requests ) , taxpayers generally concentrate on intra - group transactions that have significant volume and a large amount of tax at stake in applying for an APA . It is not rare that an APA takes two or three years until concluded .
 There are no CFC rules in Gibraltar . However , under the general anti - avoidance provision in our Tax Act , the Commissioner may disregard any CFC or transaction with such CFC where the Commissioner believes that it is fictitious or artificial .
 Interest paid on a loan by a company to related parties ( which are not themselves a company ) or loans where security is provided by related parties , where the ratio of the value of the loan capital to the equity of the company exceeds 5 to 1 is considered as a dividend payment and thus not a deductible expense for tax purposes .
 The amount of interest payments to connected persons which is in excess of that payable at “ arm ’s length ” is deemed to be a dividend .
 ( iii ) 	 75 % of the pre expenses profit .
 The UK CFC regime is based on rules designed to prevent diversion of UK profits to low tax territories . Where UK profits are diverted to a CFC , those profits are apportioned and charged on a UK corporate interest - holder that holds at least a 25 % interest in the CFC . There are a number of exemptions to reflect the fact that the majority of CFCs are established for genuine commercial reasons . The Finance Act 2004 abolished the separate thin capitalization requirements that had existed previously and subsumed them within the general transfer pricing rules in the Taxation ( International and Other Provisions ) Act 2010 ( TIOPA 2010 ) .
 The UK transfer pricing ( TP ) regime is contained in Parts 4 and 5 of Taxation ( International and Other Provisions ) Act 2010 . The UK TP regime must be considered in light of the recently implemented Diverted Profits Tax ( DPT ) rules , which were introduced by the Finance Act 2015 . There is also an advanced pricing agreement ( APA ) programme through which unilateral , bilateral and multilateral APAs can be obtained . The process by which such an agreement can be obtained is detailed in HMRC ’s Statement of Practice 2/2010 . HMRC will determine the taxpayer ’s DPT position before agreeing to an APA .
 As a result of the Starbucks and Apple decisions , any business which has secured a favourable APA could , potentially , be at risk of having those arrangements reviewed under the State Aid rules and be faced with having to make significant payments to repay tax benefits received under APAs that , allegedly , do not comply with State Aid rules .


text:
The HST team will be making a final decision on observing SDSS J153817.35+512338.0 based on the observations of May 13/14 and 14/15, and observations from the following two nights will also be essential. Close monitoring of 1RXS J105010.3-140431 through May 18 is requested. SDSS J153817.35+512338.0 is V=18.6 at minimum and its magnitude at maximum is unknown.
This date is revised from the preliminary date given in AAVSO Special Notice #351. Giving SDSS J153817.35+512338.0 highest priority, please also monitor DT Oct; close monitoring May 17 through 25 is essential. DT Oct is V=16.5 at minimum and V=11.8 at maximum.
Please report observations as soon as possible to the AAVSO International Database using the names SDSS J153817.35+512338.0 and DT Oct, respectively. If an outburst is detected, please report observations immediately. Many thanks!

tokenized:
The HST team will be making a final decision on observing SDSS J153817.35 + 512338.0 based on the observations of May 13/14 and 14/15 , and observations from the following two nights will also be essential . Close monitoring of 1RXS J105010.3 - 140431 through May 18 is requested . SDSS J153817.35 + 512338.0 is V=18.6 at minimum and its magnitude at maximum is unknown .
 This date is revised from the preliminary date given in AAVSO Special Notice # 351 . Giving SDSS J153817.35 + 512338.0 highest priority , please also monitor DT Oct ; close monitoring May 17 through 25 is essential . DT Oct is V=16.5 at minimum and V=11.8 at maximum .
 Please report observations as soon as possible to the AAVSO International Database using the names SDSS J153817.35 + 512338.0 and DT Oct , respectively . If an outburst is detected , please report observations immediately . Many thanks !


text:
Send a Press Release to the WCQS-FM in Asheville North Carolina Call or fax WCQS-FM with your news story, press release, or your public relations (PR) idea.
*Please note: This Asheville North Carolina news media information was compiled from a variety of database sources. Asheville North Carolina public relations info is always changing. We do our best to keep our listings current. So, this Asheville North Carolina press release news is deemed accurate, but not guaranteed.
Contact the News Director for the WCQS-FM with your newsworthy story and news headlines for the Asheville North Carolina area.
Free press and publicity tips for Asheville North Carolina? Submit a press release to WCQS-FM. This will guarantee you Asheville North Carolina news headlines in WCQS-FM.
Send us your Asheville North Carolina Press Release.

tokenized:
Send a Press Release to the WCQS - FM in Asheville North Carolina Call or fax WCQS - FM with your news story , press release , or your public relations ( PR ) idea .
 * Please note : This Asheville North Carolina news media information was compiled from a variety of database sources . Asheville North Carolina public relations info is always changing . We do our best to keep our listings current . So , this Asheville North Carolina press release news is deemed accurate , but not guaranteed .
 Contact the News Director for the WCQS - FM with your newsworthy story and news headlines for the Asheville North Carolina area .
 Free press and publicity tips for Asheville North Carolina ? Submit a press release to WCQS - FM . This will guarantee you Asheville North Carolina news headlines in WCQS - FM .
 Send us your Asheville North Carolina Press Release .


text:
Interested in AA in Bible? Admissions officers are waiting to hear from you!
Southwestern Assemblies of God University - AA in Bible is an online school located in Waxahachie, TX.

tokenized:
Interested in AA in Bible ? Admissions officers are waiting to hear from you !
 Southwestern Assemblies of God University - AA in Bible is an online school located in Waxahachie , TX .


text:
The Pasadena Board of Education asked School District staff to make “stronger recommendations” for spending a new yearly influx of $7 million in revenue resulting from the passage of Measure J after reviewing an initial listing at last week’s Special Board Meeting.
“We don’t want a wish list, we want something specific,” said Board Member Scott Phelps.
The Board was focused on responding to a request for funding priorities from Mayor Terry Tornek, who chairs a joint ad hoc committee composed of Pasadena City Councilmembers and members of the Pasadena School Board working out how to implement Measure J.
We need a game plan for how the Measure J revenues should be allocated, Tornek had said at the Ad Hoc Committee’s initial meeting last December.
Before last Thursday night’s meeting, School Board Member Kim Kenne said she believed the Ad Hoc Committee wanted to get a consensus from the School Board on the use of the fresh tax revenue funds.
But at the meeting, Board Member Elizabeth Pomeroy asked “What exactly does the City Council want from us?” in terms of spending plans.
“This,” said new Pasadena Unified Chief Business Officer Leslie Barnes’, referring to a report she prepared for the meeting.
Barnes’ report named six categories of funding—Signature programs, restoring funding of positions and funding shifts from the Fiscal Stabilization Plan; adjusting the budget for enrollment projections, backfilling lost grant funding, technology needs, and increasing reserves to District funds.
The signature programs include the International Baccalaureate programs, Dual-language immersion, STEM and STEAM Magnet schools, visual and performing arts programs, math academy, and the International Academy, all of which suffered cuts over the past year.
The report also recommends restoring the $750,000 Special Education reduction, as well as restoring Early Childhood TOSA teaching positions.
Both Board member Phelps and Michelle Richardson Bailey spoke in favor of restoring teaching positions.
Board Member Patrick Cahalan also recommended raising the $2.7 million dedicated to signature programs, to $3 million.
Both PUSD President Lawrence Torres and Board Member Kimberly Kenne spoke on the danger, however, of making decisions that could not be reversed.
The revised spending recommendations will be discussed at the PUSD’s next board meeting, set for January 24.

tokenized:
The Pasadena Board of Education asked School District staff to make “ stronger recommendations ” for spending a new yearly influx of $ 7 million in revenue resulting from the passage of Measure J after reviewing an initial listing at last week ’s Special Board Meeting .
 “ We do n’t want a wish list , we want something specific , ” said Board Member Scott Phelps .
 The Board was focused on responding to a request for funding priorities from Mayor Terry Tornek , who chairs a joint ad hoc committee composed of Pasadena City Councilmembers and members of the Pasadena School Board working out how to implement Measure J.
 We need a game plan for how the Measure J revenues should be allocated , Tornek had said at the Ad Hoc Committee ’s initial meeting last December .
 Before last Thursday night ’s meeting , School Board Member Kim Kenne said she believed the Ad Hoc Committee wanted to get a consensus from the School Board on the use of the fresh tax revenue funds .
 But at the meeting , Board Member Elizabeth Pomeroy asked “ What exactly does the City Council want from us ? ” in terms of spending plans .
 “ This , ” said new Pasadena Unified Chief Business Officer Leslie Barnes ’ , referring to a report she prepared for the meeting .
 Barnes ’ report named six categories of funding — Signature programs , restoring funding of positions and funding shifts from the Fiscal Stabilization Plan ; adjusting the budget for enrollment projections , backfilling lost grant funding , technology needs , and increasing reserves to District funds .
 The signature programs include the International Baccalaureate programs , Dual - language immersion , STEM and STEAM Magnet schools , visual and performing arts programs , math academy , and the International Academy , all of which suffered cuts over the past year .
 The report also recommends restoring the $ 750,000 Special Education reduction , as well as restoring Early Childhood TOSA teaching positions .
 Both Board member Phelps and Michelle Richardson Bailey spoke in favor of restoring teaching positions .
 Board Member Patrick Cahalan also recommended raising the $ 2.7 million dedicated to signature programs , to $ 3 million .
 Both PUSD President Lawrence Torres and Board Member Kimberly Kenne spoke on the danger , however , of making decisions that could not be reversed .
 The revised spending recommendations will be discussed at the PUSD ’s next board meeting , set for January 24 .


text:
This is a placeholder page for Linda Herbert, which means this person is not currently on this site. We do suggest using the tools below to find Linda Herbert.
You are visiting the placeholder page for Linda Herbert. This page is here because someone used our placeholder utility to look for Linda Herbert. We created this page automatically in hopes Linda Herbert would find it. If you are not Linda Herbert, but are an alumni of Douglas High School East Douglas, MA, register on this site for free now.

tokenized:
This is a placeholder page for Linda Herbert , which means this person is not currently on this site . We do suggest using the tools below to find Linda Herbert .
 You are visiting the placeholder page for Linda Herbert . This page is here because someone used our placeholder utility to look for Linda Herbert . We created this page automatically in hopes Linda Herbert would find it . If you are not Linda Herbert , but are an alumni of Douglas High School East Douglas , MA , register on this site for free now .


text:
What makes our storybooks special is that your child is the hero! We personalize each book using your child's name and appearance.
Your donations and book orders help provide free personalized STEM books to classrooms of girls in local after-school STEM-enrichment programs!
Your donations and book orders fund our education and outreach events to share our love and excitement for STEM through hands-on learning activities.

tokenized:
What makes our storybooks special is that your child is the hero ! We personalize each book using your child 's name and appearance .
 Your donations and book orders help provide free personalized STEM books to classrooms of girls in local after - school STEM - enrichment programs !
 Your donations and book orders fund our education and outreach events to share our love and excitement for STEM through hands - on learning activities .