Results 191 to 200 of about 3,784,238 (242)

Lithography‐Compatible Conductive Metal–Organic Frameworks for Scalable Electronics

open access: yesAdvanced Materials, EarlyView.
Conductive MOF thin films are integrated as gate electrodes in semiconductor devices through a photolithography‐compatible patterning strategy. CVD‐grown 2D MOF thin films enable stable operation across bottom‐gate MoS2/MoTe2 field‐effect transistors and top‐gate IGZO arrays, highlighting the potential of conductive MOFs as functional electronic ...
Hyeonwoo Lee   +9 more
wiley   +1 more source

The Timely Resolution of Mutual Agreement Procedure Disputes – Secrets of Success?

open access: yesBulletin for International Taxation, 2023
In this article, the author considers the secrets of success regarding the timely resolution of mutual agreement procedure disputes via an examination of key factors exhibited by countries that have received OECD awards for this specific achievement ...
Markham, Michelle
exaly   +3 more sources
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ECJ and Mutual Agreement Procedures

Intertax, 2014
The Mutual Agreement Procedure (Article 25 OECD Model Convention) is a rather helpful tool to sort out all kind of interpretation conflicts between two contracting states. If tax treaties are in an intra-Union setting replaced by a Directive and if the content of the OECD Model Convention is transformed in such a Directive, the Court of Justice would ...
exaly   +3 more sources

Transfer Pricing and Mutual Agreement Procedures

International Transfer Pricing Journal, 2009
The recently issued Decree on the Mutual Agreement Procedure and the inclusion of a revised arbitration clause in the new tax treaty with the United Kingdom clearly demonstrate the importance given by the Netherlands to solving transfer pricing discussions.
B.vander Klok, T. Elshof
openaire   +1 more source

The Revised Mutual Agreement Procedure and Recent Developments in Turkey

European Taxation, 2022
Turkey has enacted new Mutual Agreement Procedure (MAP) regulations (Law 7338 of 14 October 2021) in an effort to facilitate the resolution of international tax disputes, improve legal certainty and conform to the minimum standard of Action 14 of the OECD/G20 BEPS Project.
openaire   +1 more source

The Mutual Agreement Procedure in International Taxation

2020
The globalization of economic and multinational business structures has exacerbated the problem of substantive overlapping national tax laws in recent decades. Double taxation has a negative impact on international economic transactions because it leads to the suboptimal allocation of capital and affects the cross-border exchange of goods.
openaire   +1 more source

Mutual Agreement Procedure and Foreign Direct Investments: Evidence from Firm-level Data

SSRN Electronic Journal, 2023
This paper investigates the association between the effectiveness of mutual agreement procedures provided for in bilateral tax treaties (MAP) and foreign direct investments by analyzing MAP statistics and distinct MAP components. Using firm-level ownership data, we find that MNEs invest more frequently in countries with good MAP policy structures and ...
Petutschnig, Matthias, Zhang, Xixi
openaire   +1 more source

New Spanish regulation on the mutual agreement procedure

Bulletin for International Taxation, 2009
In November 2008, Spain issued a new regulation on the mutual agreement procedure (MAP)which applies to two procedures: the MAP under Spain's tax treaties and the procedure governed by the EC Arbitration Convention. This article examines and analyses the new regulation, including (among other things) its scope and structure, its common provisions, the ...
openaire   +1 more source

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