Results 231 to 240 of about 61,912 (300)

Maximizing Value through Arbitral Power within the International Tax Dispute System

World Tax Journal, 2023
This article provides a theoretical foundation with potential for direct practical implementation on the use of arbitral powers within international tax dispute resolution for the benefit of arbitrators and competent authorities. First, it introduces the
S. Castagna
semanticscholar   +1 more source

Proposition for an AFCFTA-based Tax Dispute Court for the Timely Resolution of Commercial Tax Disputes

African Multidisciplinary Tax Journal, 2023
The African Continental Free Trade Area (AfCFTA) Agreement is promoted as a developmental game-changer set to foster an impressive growth in intra-African trade.
Marie-Louise Fehun Aren
semanticscholar   +1 more source

An Unfinished Patchwork: An Assessment of the Current International Tax Dispute Resolution System from a Developing Country Perspective

World Tax Journal, 2022
The twenty first century has seen a number of rapid developments in the international tax dispute resolution system, culminating with the Pillar One tax certainty block as proposed by the Inclusive Framework on BEPS.
N. Quiñones
semanticscholar   +1 more source

A Global Analysis of Tax Treaty Disputes

2017
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax ...
  +4 more sources

International Tax Dispute Resolution in Light of Pillar One: New Challenges and Opportunities

Bulletin for International Taxation, 2021
The “Blueprint on Pillar One” relies on effective and binding dispute prevention and/or resolution mechanisms. Key aspects of these mechanisms pose significant challenges to the traditional system of international tax dispute resolution (ITDR ...
S.E. Malamis, Q. Cai
semanticscholar   +1 more source

Tax Dispute Analysis In The Perspective Of Web-Based Tax Audit And Collection PEM

International Journal of Scientific and Research Publications (IJSRP), 2021
This study aims to uncover and explore new meanings about tax disputes from the perspective of the parties directly involved, namely the Tax Auditor. Phenomenology is also used as a research method to explore the meaning.
Joni S.S.T Bkp
semanticscholar   +1 more source

Legal Discovery in Indonesia’s Tax Dispute Framework

Journal of Human Rights Culture and Legal System
There exists a normative disharmony between the Tax Court Law, the Judicial Power Law, and the General Provisions and Tax Procedures (KUP) Law, which adversely affects the independence and authority of the Tax Court in adjudicating tax disputes. This
Efendi Ibnususilo, Fithriatus Shalihah, Nisa Istiani, Faqiah Nur Azizah   +3 more
semanticscholar   +1 more source

Australian Federal Court Judge's Arguments in Transfer Pricing and Royalty Tax Dispute Decision in PepsiCo Case

International Journal of Sustainability in Research
This study analyses the main arguments presented by the Federal Court of Australia in the tax dispute over transfer pricing and royalty taxation in the PepsiCo case. Using a doctrinal research methodology, it examines the legal reasoning behind the Court'
Mohammad Wangsit Supriyadi, A. Suharsono
semanticscholar   +1 more source

The Influence of Tax Dispute Resolution Mechanisms: Legal Contributions of Tax Consultants and Tax Attorneys in Indonesia

Ilomata International Journal of Tax and Accounting
This study examines the roles of tax consultants and tax attorneys in resolving tax disputes in Indonesia, emphasizing their contributions to tax compliance, dispute resolution, and litigation.
Heriantonius Silalahi, Nandi Maulana, Lenny Ana, Budi Kurnia   +3 more
semanticscholar   +1 more source

Toward a Coordinated Approach to the Suspension of Tax Collection to Improve the Effectiveness of International Tax Dispute Resolution within the European Union

European Taxation
In this article, the authors analyse the extent to which the suspension of payment mechanism is available to taxpayers in respect of mutual agreement procedures within the European Union.
B. Gibert, D. Gutmann, C. Pasquier, A. Sage   +3 more
semanticscholar   +1 more source