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Law & Business

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EC Otmar Thömmes, Susan LyonsBelgium Dirk Deschrijver, Prof. André J.J. SpruytFrance Pierre-Yves BourtouraultGermany Manfred Günkel, Prof. Dr. Otto Jacobs, Mr. Michael WichmanHong Kong Michael A. OlesnickyHungary Mr. Daniel DeákIndia Gagan K. KwatraIreland Mary WalshItaly Dr. Guglielmo Maisto, Dr. Siegfried MayrJapan Mr. Daisuke Kotegawa, Prof. Hiroshi Kaneko, Masatami OtsukaNetherlands Prof. Sijbren Cnossen, Prof. Kees van RaadPortugal Prof. Gloria Teixeira, Prof. José Luis Saldanha SanchesSpain Juan José Bayona de Perogordo, Maria Teresa Soler RochSweden Maria HillingSwitzerland Daniël Lüthi, Dr. Robert DanonUK Malcolm GammieUSA Prof. William B. Barker

Transfer Pricing Planning with Accuracy and Control

Rainer Zielke*

Traditionally the Comtax® System provides not only current in-depth information on numerous national systems of taxation, but also quantifies cross-border payment transfers, and thus allows both a quick access on relevant detail knowledge and a direct comparison of different scenarios. This has nowbeen upgraded by the new Comtax solution for transfer pricing were the arm’s length principle, the definition of related companies, transfer pricing meth-ods, business restructuring and dispute resolution are taken into consideration. The theory of international tax planning provides objectives and conceptsof international tax planning and demands expertise in current and reliable information – also on transfer pricing. Comtax® System and Comtax®TP Tool are now jointly able to cover all aspects of international tax planning.

1 INTRODUCTION

Countries compete with their tax regimes for internationalinvestors, especially with lower tax rates. Internationalinvestors practice tax arbitrage in order to reduce their taxburden. Today, transfer pricing belongs to the most demand-ing fields of activity for the international tax planner. If dif-ferent systems of taxation have to be taken into consideration– including e.g., anti-avoidance legislation –, the level aswell as the liability risk of consultancy increase. When insuch a context where interactions on the level of a cross-border operating group of affiliated companies increase, theadditional complexity takes up an extent that needs to beconsidered, which is problematic without computer-basedsystems. However, most of these systems are usually limitedto providing basic information on corporate income tax sys-tems, tax rates and the treaty network, whereas Comtax®System1 provides not only current in-depth information onnumerous national systems of taxation, but also quantifiescross-border payment transfers, and thus allows both a quickaccess on relevant detail knowledge and a direct comparisonof different scenarios.2 This has now further been upgradedby the new Comtax solution for transfer pricing – Comtax®TP Tool.

The main issue of this study is the question on theproblem-solving contribution of Comtax® TP Tool. In a

first step, the objectives and concepts of international taxplanning and the importance of current and reliable infor-mation is examined, because it sets the benchmark for theevaluation of Comtax. Thereupon and in a second step, thenew Comtax solution for transfer pricing is introduced, andin a third step, the possibilities of usage of the new Comtaxsolution for transfer pricing is outlined and finally evaluatedon the basis of the theory of international tax planning.

2 OBJECTIVES AND CONCEPTS OF

INTERNATIONAL TAX PLANNING AND THE

IMPORTANCE OF CURRENT AND RELIABLE

INFORMATION

2.1 Reduction in the EffectiveTax Rate as theMain Corporate Objective

As outlined earlier, an important ratio to measure the perfor-mance of a company, of its management and of its tax depart-ment, is the ETR.3 By the spread of international accountingrules, the ETR has gained increasingly inimportance. TheETR is a ratio specific to the company on the extent of thecorporate income tax of a group of affiliated companies. Con-solidated financial statements, that are prepared accordingto international accounting rules, are – according to the

Notes* Prof. Dr Rainer Zielke is Professor in Business Economics, Norwegian tax law and international taxation at Østfold University College in Halden, Norway www.fag.hiof.no/

~rainerz. The author can be reached at [email protected] The Comtax system and the Comtax® TP Tool are products of Comtax AB, Helsingborg, Sweden, 2013. www.comtaxit.com. All further comments are based on the software

version 11.1 [updated in March 2013].2 For a review of the classic Comtax® System, see Wolfgang Kessler & Torben Petersen, Steuerplanung mit Comtax, 16 Internationales Steuerrecht 815–818 (2007); Rainer Zielke,

International Tax Planning with Comtax, 37 Intertax 197–206 (2009).3 See Rainer Zielke, Internationale Steuerplanung zur Optimierung der Konzernsteuerquote, 59 DER BETRIEB 2585 (2006); Rainer Zielke, International Tax Planning with Comtax, 37

Intertax 198 (2009).

ARTICLE

542INTERTAX, Volume 41, Issue 10© 2013 Kluwer Law International BV, The Netherlands

International Financial Reporting Standards (IFRS formerlyIAS) No. 12 – under the obligation to develop this measure.The usage of the ETR as control and conduct measure of theoperative tax policy and tax planning is therefore an under-standable reaction of the tax department.

The ETR according to IAS 12.86 is defined as quotient ofactual (Tgroup) and deferred (Tgroup/deferred) tax expenses onincome of the group and the result before taxes on income ofthe group (INCgroup):

ETR = (Tgroup + Tgroup/deferred)/ INCgroup.

Actually, the prerequisite was established only by integra-tion of deferred taxes into the tax expenses, the increasingdeviation between commercial balance sheet and tax balancesheet that a sensible connection exists between tax expensesand income before taxes on income and thus the ETR couldbecome an expressive measure.

The national tax types, tax rates, taxable basis as well ascorporate income tax systems have an effect on this ratiowith varying weight. So, in the tax expenses solely the cor-porate income taxes are considered, that are levied on thelevel of all territorial authorities of a country – home andabroad. Taxes on non-income values are by contrast not con-sidered. Thus of the tax rates only the corporate income taxrates are relevant.

2.2 Objectives and Concepts

International tax planning in a multinational group of affili-ated corporations aims at the minimization of the ETR bymaking use of international tax differentials, and especiallyof advantageous national tax law and advantageous tax trea-ties. International tax planning strategies4 can, with regardto the number and the kind of relationships of the includedgroup units, be divided into:

– parent-subsidiary strategies, which make use of twogroup units;

– holding strategies, which make use of at least three groupunits; and

– indirect-ownership strategies, which make use of at leastthree groups units.

These strategies can, with regard to the location of profitrealization, again be divided into:

– repatriation strategies, where profit realization takesplace in the parent company; and

– allocation strategies, where profit realization takes placein the subsidiary.

Transfer pricing strategies are to be classified as:

– allocation strategy, if a parent company in a high-taxcountry pays high transfer prices for the delivery of goodsor services purchased from its subsidiary in a low-taxcountry to reduce taxes in the high-tax country; and as

– repatriation strategy, if a parent company in a low-taxcountry pays low transfer prices for the delivery of goodsor services purchased from its subsidiary in a high-taxcountry to reduce taxes in the high-tax country.

2.3 Importance of Current and ReliableInformation

The choice of the right strategy and – coherent with that –of the right location is a most complex problem. Importantreasons for this are the variety of the national systems of taxa-tion, its speed of changes as well as the numerous possiblecombinations of relevant treaties. Merely the quantity ofdata needed suggests thinking about computer-based prob-lem solving, that puts together all relevant information inform of a database and that would point out to the user pos-sible traps of national tax law. Besides, it is favourable thatinternational tax planning with holding companies is aclearly structured mathematical task, as principally againand again the same basic components are used and combinedwith each other. Therefore, computer-based systems cancompletely concentrate on what computers can best – searchbig quantities of data, make calculations and edit them inform of tables and diagrams.

Many examples of the necessity of current and reliableinformation on the basis of an effective and high-qualitytransfer pricing solution can be outlined. There has been avisible increase in the number of governmental tax author-ity audits worldwide, resulting into a rise in transfer pricingreassessment and adjustments. One of the later and promi-nent cases are found in Denmark, where a Danish blue-shipcompany was audited by the Danish tax authorities result-ing into that the company had its transfer pricing adjustedof almost half a billion euros tax payable as a consequence.5

Notes4 See Rainer Zielke, International Tax Planning with Tax Havens – Objectives and Strategies in a Multinational Group of Affiliated Corporations, 65 Bull. Intl. Taxn. 81 (2011); Rainer

Zielke, International Tax Planning with Comtax, 37 Intertax 198(2009).5 See Nikolaj Bjørnholm & Anders Bang, Denmark’s New Focus on Transfer Pricing, News Analysis (7 Feb. 2013).


543

3 TRANSFER PRICING INFORMATION AND

CALCULATIONS OF 129 JURISDICTIONS OF

THE WORLD AS A SUBJECT OF THE NEW

COMTAX SOLUTION FOR TRANSFER PRICING

3.1 Overview

Comtax® TP Tool enables the international tax planner tomodel the flow of payments through the companies of a mul-tinational group. The results it produces allow the interna-tional tax planner to find the most tax-efficient method ofmoving funds through the organization. The basic model-ling data is obtained from a database that contains the taxa-tion rules of all the major countries in the world – 129jurisdictions. Comtax AB regularly updates the informationin this database which allow the user to have the latest dataat his/her fingertips and immediately process the content,resulting into transparent reports of its meaning that can besaved, exported and printed. Comtax® TP Tool uses theComtax platform, where the effect of the tax legislation ineach country on the funds being transferred is shown as anindex number. In situations where more than one strategy ispossible, the tool displays the most effective alternatives toallow you to make your decision. This information can thenbe used when modelling your transfer pricing structure. Byadding intra-group transactions, applicable transfer pricingmethods and mark-ups Comtax® TP Tool provides the userwith the transfer price of goods, services, licensing or financ-ing and ultimately display the tax implication.

The country-related transfer pricing information and cal-culations lead to an effective transfer pricing policy on thebasis of information on the arm’s length principle and defi-nition of related companies, transfer pricing methods, busi-ness restructuring and transfer pricing, dispute resolution aswell as mathematical approaches.

The most important aspects considered are outlined asfollows.

3.2 Arm’s Length Principle and Definition ofRelated Companies

The Arm’s length principle (ALP) is the central principleapplied in the context of transfer pricing.6 The OECD refersto it as the ‘international standard that OECD Membercountries have agreed should be used for determining trans-fer prices for tax purposes’. The principle requires associatedenterprises to charge the same prices, royalties and other feesin relation to a controlled transaction that would be chargedby independent parties in an uncontrolled transaction inotherwise comparable circumstances. Such prices are gener-ally referred to as ‘arm’s length prices’.

Transfer pricing methods and procedures are recom-mended in the OECD Report on transfer pricing guidelinesfor multinational enterprises and tax administrations(OECD Transfer Pricing Guidelines (TPG)). The report wasissued in July 1995 by the OECD Committee on FiscalAffairs and has been updated by chapters and annexes on spe-cial subjects such as cost contribution arrangements (CCAs),the transfer pricing monitoring programme, mutual agree-ment procedure (MAP) and advance pricing arrangements(APAs). Transfer pricing guidelines for global trading opera-tions were issued in January 1998 in the OECD Report ontaxation of global trading of financial instruments. In 2010,the Transfer Pricing Guidelines were substantially revisedand amended to include recommendations on the selectionof the most appropriate transfer pricing method in the cir-cumstances of the case, the practical application of transac-tional profit methods (the transactional net margin methodand the profit split method) and carrying out a comparabil-ity analysis. Furthermore, a new Chapter IX on the transferpricing aspects of business restructuring was added.

In the context of the ALP, some terms have to be defined:An APA is an arrangement that determines, in advance ofcontrolled transactions, an appropriate set of criteria for thedetermination of the transfer pricing for those transactionsover a fixed period of time. A CCA is a framework agreedamong companies to share the costs and risks of developing,producing, or obtaining assets, services or rights, and todetermine the nature and extent of the interests of each par-ticipant in the results of the activity of developing, produc-ing, or obtaining those assets, services or rights.

These standards also affect related companies (also calledassociated companies) that are not in an arm’s-length rela-tionship. This could be the situation where both companiesare part of the same business group or where there are familyor personal ties between officials of two or more companies.

3.3 Transfer Pricing Methods

The most important transfer pricing methods that are bothdocumented and calculable for the 129 jurisdictions coveredby Comtax are to be described as follows:

– CUP (comparable uncontrolled price method): This is a trans-fer pricing method that compares the price for property orservices transferred in a controlled transaction to the pricecharged for property or services in a comparable uncon-trolled transaction in comparable circumstances. InComtax, this can be calculated both with a fixed rate andpercentage rate.

– Cost+ (cost-plus method): This is a transfer pricing methodused to determine the arm’s length price for the transferof property or services. A gross profit mark-up is added to

Notes6 See OECD Model Art. 9; OECD Transfer Pricing Guidelines.

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544

the cost of producing the property or providing the ser-vices to arrive at the arm’s length price. The gross profitmark-up is determined by reference to the functions per-formed by the taxpayer (taking into account the assetsused, risks assumed, and market conditions) or by refer-ence to comparable uncontrolled transactions. Thismethod is commonly used in relation to the sale of semi-finished products (e.g., in the context of contract manu-facturing) or the supply of services between relatedparties.

– Resale- (resale price method): This is a transfer pricingmethod based on the price at which a product that hasbeen purchased from a related company is resold to anindependent enterprise. The resale price is reduced by theresale price margin. The resale price methods (RPM) is atransfer pricing method under which the arm’s lengthprice for property purchased from an associated enterpriseis determined by reference to the resale price margin real-ized from sale of the same or similar property in compa-rable uncontrolled transactions. The resale price marginso determined is subtracted from the resale price in theuncontrolled transaction to arrive at the arm’s lengthprice for the purchase from the associated enterprise. TheRPM is normally used in cases where tangible property ispurchased from an associated enterprise and resold to anindependent enterprise and the reseller has not added sub-stantial value to the property by the use of intangibles orotherwise.

– TNMM/CPM (Transactional net margin method/comparableprofits methods): This is a transfer pricing method underwhich the arm’s length price is determined by reference to‘objective levels of profitability’ that are realized byuncontrolled taxpayers engaged in similar businessactivities under similar circumstances. These are referredto as profit level indicators (PLIs) and include the EBIT%and MTC (mark-up on total costs) ratios of operatingprofits to operating assets, the ratio of operating profits tosales and the ratio of gross profits to operating expenses-.The EBIT% as a TNMM corresponds to the cost of goodssold (COGS), operating expenses (OPEX) or both wherethe margin equals the set margin of the total revenue. TheMTC is a transactional profit split method that examinesthe net profit margin relative to an appropriate base that ataxpayer realizes from a controlled transaction.

– PSM (profit split method): The transactional PSM identifiesthe combined profit to be split for the related companiesand then splits those profits between the related compa-nies based on economically valid basis of COGS andOPEX that approximates the division of profits thatwould have been expected between unrelated companies.

The expression ‘traditional transaction methods’ is used bythe OECD in the context of transfer pricing, to refer to thetraditional methods for determining arm’s length prices forspecified transactions. The main types are the comparableuncontrolled price method, the cost-plus method and theresale price method. Such methods may be distinguishedfrom ‘other methods’, such as the profit split method or theglobal formulary apportionment method.

3.4 Dispute Resolution

A MAP is an administrative procedure provided for in taxtreaties for resolving difficulties arising out of their applica-tion. The procedure is most commonly used in cases ofdouble taxation that are not clearly resolved by the treaty(e.g., as regards to allocation of head office expenses, arm’slength allocation of profits between associated enterprises,etc.). Treaties occasionally provide for resolution of corpo-rate dual residence by way of the MAP. The procedure mayalso be used to resolve problems relating to the interpreta-tion or application of the treaty and provides the basis forinformal communications between treaty countries.Although the taxpayer is authorized to initiate the proce-dure the parties to the procedure are the competent authori-ties of the contracting states (frequently the Ministry ofFinance or its authorized representatives). The procedure isgenerally expressed to apply in addition to the remediesavailable under domestic law. While there generally is a timelimit within which claims should be made, there is generallyno time limit within which they should be resolved, noreven an obligation on the competent authorities to reach asolution.

An alternative dispute resolution is a reference to varioustechniques or procedures through which disputes may beresolved without recourse to traditional litigation. In a taxcontext, the term encompasses prospective dispute resolu-tion, e.g., by way of APAs, administrative appeals proce-dures, mediation, arbitration or consolidation of issues orprocedures (such as simultaneous appeals and competentauthority procedures).

4 POSSIBILITIES OF USAGE OF THE NEW

COMTAX SOLUTION FOR TRANSFER PRICING

4.1 Examples for the New Solution forTransfer Pricing with Comtax

Comtax® TP Tool provides both access to the transfer pric-ing database for anti-avoidance legislation information andto the transfer pricing calculation tool for intra-group


545

transactions and cross-border payment transactions.Comtax TP® Tool conducts four steps to perform transferpricing calculations:

– Step 1: Selecting companies: In order to start a calculation,one needs to choose the source country i.e., ‘Provider/Vendor’ and the ‘Recipient’.

– Step 2: Adding internal transactions: As one clicks next, onewill automatically be taken to the next step i.e., ‘Transac-tion’. Here one will be able to choose the type of transac-tion, the transfer pricing method and the determinationof payment that one would like to calculate. For anexample see Figure 1 below:

The following intra-group transactions might be chosen:

– Type of transaction (The type of transaction determinesthe forms of payments available. It can also limit the TPmethods and instruments available):

⇒ Sale of goods

⇒ Provision of services

⇒ Licensing (for royalty payments)

⇒ Provision of financing

⇒ Dividend

– Type of service and licensing (if applicable):

⇒ Management service fee

⇒ Technical service fee

⇒ Patent

⇒ Trademark

⇒ Copyright

– Transfer pricing method:

⇒ CUP

⇒ Cost+

⇒ Resale-

⇒ TNMM/CPM

⇒ PSM

⇒ Other

– PLI’s or Profits to be Split (based on the selected TPmethod):

⇒ Fixed

⇒ Percentage

⇒ EBIT%

⇒ MTC

⇒ GP Allocation (Gross profit allocation)

⇒ EBIT Allocation

– Tested Party (the Provider/Vendor or the Recipient ifapplicable)

– Select type of Expenses (COGS or OPEX if applicable)

– Value (the margin that will be applied)

The amount of intra-group transactions is not limited.However, in order to avoid intra-group transaction rulesconflicting with each other, two transactions cannot have thesame tested party with the same Profit PLI. This also appliesfor such profit split transactions that would cause a similarconflict. In case the same country should be used as testedparty with the same PLI on several transactions, one shouldadd a separate country for each transaction.

– Step 3: Adding External Revenues, Costs and Expenses(for both provider/ vendor and recipient):

– Revenue (ext.) (possible external revenue from unre-lated parties)

– COGS (ext.) (possible external expenses to unrelatedparties)

– OPEX (ext.) (possible external expenses to unrelatedparties)

– Interest expenses (ext.) (external interests expensesand/or income if applicable from/to unrelated parties-)The actual transfer price applied is based on thechoice of type of transaction, TP method and marginand be allocated into the cells marked as COGS (int.),OPEX (int.), interest expense (int.) thus be the intra-group expense, and correspond to the correct intra-group revenue i.e., sale of goods, provision of services,royalties or interest income.

– Step 4: Transactional overview: In the Overview of thecalculation, one can easily verify the set up one has madein the choice of countries, type of transaction, transferpricing method and determination of payment, externalexpenses, etc. and changes may be made at this stage.

Comtax® TP Tool provides lots of features. One of the mostimportant features is the Profit & Loss window. It is the mainwindow in the Comtax® TP Tool and where one preparesthe model by selecting the countries, entering external rev-enues and expenses and setting up your intra-group transac-tions. Thereafter one may calculate the effect of the modeland find the tax implication for each individual country andfor the whole group as a consolidated result. In the list oftransactions, one may delete and edit the transactions andthen recalculate to see the effect of the changes. For anexample see Figure 2 below:

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4.2 Features and Benefits Analyses

Comtax® TP Tool has been designed to allow the interna-tional tax planner to gain the maximum benefit from it inthe shortest time possible. Despite its sophistication, itsdesign ensures that it is easy to learn and to use. A system ofmenus and special keys allows controlling what the tooldoes. The menus and dialogues in the tool follow the well-established conventions of the Windows® environment.Using this software, one can concentrate on the task one isperforming, not on the tool one is using to perform it.

The TP Wizard will assist the international tax plannerstep-by-step to insert the first two countries, set up the firstintra-group transaction and plug in the values into the Profitand Loss sheet. One may of course insert additional countriesand transactions using the Profit and Loss window.

The main features are as follows:

– Laws and regulations: Comtax® TP Tool embodies all therecognized transfer pricing methods and transactions. Ithas the ability to provide a detailed audit trail that can belogged and printed. The software is built on the well-known and reliable Comtax platform, using its data toextract anti-avoidance legislations and tax rates for 129jurisdictions.

– Calculation formulas: All formulas consider the linkbetween calculations methods and tax rates. It is a naturalway to work in the feasibility study when creating guide-lines and for monitoring of current policies.

– Output: The software provides a complete overview of thecorporate tax, withholding tax and applicable tax creditfor each individual country as well as a consolidated resultfor profit and tax.

– Design: The software can be accessed instantly through theweb browser. With a graphical design and its user-friendly interface, it allows for easy simulations for anytransfer pricing calculations.

– Other features: Comtax® TP Tool calculates the tax effecton cross-border transactions on four levels for dividendrepatriation, interest-, royalty- and fee payments.

The benefits are as follows:

– Less compliance: Comtax® TP Tool offers the possibility tospend less time and resources on compliance.

– Automation: The Excel spread sheet and its manual proce-dures are no more necessary. Thus time is saved and cal-culation errors are diminished.

– More time for qualitative tax planning: Manual routine workis no more necessary. Comtax® TP Tool ensures that taxdepartments get the time needed for the qualitativeaspect of planning.

– Simulations: With the integrated tax information andfinancial formulas, it becomes easy to find the optimaltransfer pricing structure.

– Planning versus compliance: Comtax® TP Tool is the onlysolution that can minimize duplication of functions andtax leakage through planning.

– Business impact: With indisputable consistency and accu-racy, it enables monitoring, revising and planning. Itensures the correct transfer pricing position with taxresult that proves the bottom line impact of your transferpricing structure. For an example see Figure 3 below:

5 CONCLUDING REMARKS

The objectives and concepts of international tax planningdeduced at first set the benchmark for the evaluation ofComtax solutions. Comtax complies with all the objectivesand concepts of international tax planning. In additionComtax is the best provider of transfer pricing planningtechnology worldwide. Comtax® TP Tool is perfectly inte-grated into the classical Comtax solution. It is the earliermissing link in this sophisticated technology. Consequently,Comtax is now able to cover all aspects of international taxplanning. Furthermore, the strength of Comtax consists intime saving and large flexibility, which enables the interna-tional tax planner also beyond of the own experiences and ofthe known ‘standard planning solutions’ to simulate differ-ent scenarios and so to make an optimal international taxplanning. Comtax presents quickly the information relevantfor the first planning considerations and supports the han-dling particularly of multi-level group structuring. Theinformation provided by the system may always be changedmanually, so that all calculations can be carried out.

Intertax

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Editorial Board: Fred C. de Hosson, General Editor, Baker & McKenzie, Amsterdam Prof. Alexander Rust, University of Luxembourg & Touche Tohmatsu, Munich Dr. Philip Baker OBE, QC, Barrister, Grays Inn Tax Chambers, Senior Visiting Fellow, Institute of Advanced Legal Studies, London University Prof. Dr. Ana Paula Dourado, University of Lisbon, PortugalProf. Dr. Pasquale Pistone, WU Vienna University of Economics and Business and University of SalernoProf. Yariv Brauner, University of Florida, USA

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Articles can be submitted for peer review. In this procedure, articles are evaluated on their academic merit by two (anony-mous) highly esteemed tax law experts from the academic world. Only articles of outstanding academic quality will be published in the peer-reviewed section.

Contributing Editors: Author Guide

[A] Aim of the Journal

This established international tax journal offers detailed coverage of direct tax, indirect tax, and social security from both legal and economic angles, andprovides 12 issues a year of practical, up-to-date, high-level international tax information. Coverage includes all aspects of transnational tax issues. Thejournal includes authoritative, reliable content, written for tax attorneys, practitioners (litigation and transactional) in other areas where internationaltax issues are a concern, and academics.

[B] Contact Details

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[D] Peer Review

[1] At specific request by the author, an article can be submitted for peer review. [2] In this procedure, articles are evaluated on their academic merit by two (anonymous) highly esteemed tax law experts from the academic world. Only articles of outstanding academic quality will be published in the peer-reviewed section.

[E] Regular Review Process

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EC Otmar Thömmes, Susan LyonsBelgium Dirk Deschrijver, Prof. André J.J. SpruytFrance Pierre-Yves BourtouraultGermany Manfred Günkel, Prof. Dr. Otto Jacobs, Mr. Michael WichmanHong Kong Michael A. OlesnickyHungary Mr. Daniel DeákIndia Gagan K. KwatraIreland Mary WalshItaly Dr. Guglielmo Maisto, Dr. Siegfried MayrJapan Mr. Daisuke Kotegawa, Prof. Hiroshi Kaneko, Masatami OtsukaNetherlands Prof. Sijbren Cnossen, Prof. Kees van RaadPortugal Prof. Gloria Teixeira, Prof. José Luis Saldanha SanchesSpain Juan José Bayona de Perogordo, Maria Teresa Soler RochSweden Maria HillingSwitzerland Daniël Lüthi, Dr. Robert DanonUK Malcolm GammieUSA Prof. William B. Barker

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