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Dispute resolution has been regulated in a free trade agreement (FTA) so the dispute resolution procedure should follow the dispute resolution procedure established by the FTA (das sollen).
Ardiansyah Ardiansyah
doaj +4 more sources
MEANING, EVOLUTION AND ROLE OF MUTUAL AGREEMENT PROCEDURE AS A TAX DISPUTE RESOLUTION MECHANISM
The relevance of the study is determined by the fact that the issue of a tax dispute resolution is actual in the context of the globalization processes and global financial crisis state.
Pavlo Selezen
doaj +5 more sources
Mutual Agreement Procedure in Ukraine [PDF]
Mutual agreement procedure (MAP) is an important instrument for resolving disputes on taxation not in accordance with the provisions of double taxation agreements. Nevertheless, its potential was not applied widely neither by taxpayers nor by the competent authorities in Ukraine.
Liubov Kasianenko, Irina Umrykhina
core +3 more sources
The mutual agreement procedure and arbitration of double taxation disputes
It is in the interest of most states to eliminate double taxation (i.e. the payment of the same tax in two jurisdictions) oftransnational commercial enterprises.
Ilias Bantekas
doaj +4 more sources
The author traces the development of the mutual agreement procedure article and the reservations for the MAP article under the multilateral instrument. With examples drawn from some selected contracting jurisdictions holding different positions on the MLI, he illustrates how the MAP article is applied to the respective covered tax agreements and offers
alfred chan (8657094)
exaly +3 more sources
A Legal Analysis of the Structure of Dispute Resolution Mechanisms of International Tax Agreements [PDF]
As international trade is expanding, international trade and tax disputes are increasing. Under international tax agreements, there are two mechanisms for the resolution of potential disputes between contracting States.
Alireza Salehifar
doaj +1 more source
Analysis of the Application of Mutual Agreement Procedure (MAP) and Advance Pricing Agreement (APA) in Indonesia [PDF]
exaly +2 more sources
BEPS 2.0 Pillar I solutions on mechanisms of tax dispute resolutions
The purpose of the article is to present the basic assumptions of Pillar I of BEPS 2.0 and to identify areas of potential disputes on the background of the application of the new mechanisms. The article will briefly outline preventive mechanisms aimed at
Małgorzata Duda-Plesińska
doaj +1 more source
Legal nature of the agreement on the use of security measures in relation to criminal proceeding participants [PDF]
The relevance of the study is due to the presence of a set of theoretical and practical issues and gaps in the legal regulation of the agreement concluded with the protected person on the conditions of security measures, mutual obligations, and ...
Grigoryeva Natalia Vladimirovna +3 more
doaj +1 more source
Resolution of dual residence instances in the case of companies [PDF]
The application of double taxation treaties presupposes that the potential cases of dual residence have been previously resolved. For this purpose, the major model-conventions on the basis of which double taxation treaties around the globe are negotiated
Živković Lidija
doaj +1 more source

