Results 201 to 210 of about 3,784,238 (242)
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Mutual Agreement Procedure Arbitration in Developing Countries – The ASEAN Experience
Bulletin for International Taxation, 2016This article examines mutual agreement procedure (MAP) arbitration in general and in developing countries, with a particular focus on MAP experiences of the countries forming the Association of Southeast Asian Nations (ASEAN).
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Solving Double Taxation outside the Realm of a Mutual Agreement Procedure
International Transfer Pricing Journal, 2019As transfer pricing adjustments are expected to increase, so will be mutual agreement procedure requests in order to remedy the resulting double taxation. To forego the downsides of this procedure, this article suggests that a MAP should be preceded by an attempt to obtain an unilateral corresponding adjustment.
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Can the Brazilian Mutual Agreement Procedure Legislation Be Effective Domestically?
Bulletin for International Taxation, 2019This article examines the new Brazilian legislation in respect of mutual agreement procedures in light of the changes proposed by Action 14 of the OECD/G20 BEPS initiative and considers whether such legislation can be effective in the country.
D. Canen, H.de Conti
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Status of Interpretative Mutual Agreement Procedures: Case Study
European TaxationIn this note, the author examines recent and pending Dutch case law analysing the status of tax treaty mutual agreement procedures used to resolve difficulties or doubts regarding the interpretation or application of a tax treaty.
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Intertax, 2009
This article analyses whether the presence of the Mutual Agreement Procedure (MAP) in tax treaties can prevent the compulsory jurisdiction of the International Court of Justice (ICJ) in disputes in which the States involved have signed the optional clause with reservations ratione fori.
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This article analyses whether the presence of the Mutual Agreement Procedure (MAP) in tax treaties can prevent the compulsory jurisdiction of the International Court of Justice (ICJ) in disputes in which the States involved have signed the optional clause with reservations ratione fori.
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Transfer Pricing Dispute Resolution and Mutual Agreement Procedures: An Indonesian Perspective
International Transfer Pricing Journal, 2017This article examines the Mutual Agreement Procedures programme in Indonesia, including recent developments and changes in procedure, describing its advantages over other domestic dispute resolution options such as objection to the Directorate General of Taxes and appeal to the Tax Court.
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Several Issues regarding the Mutual Agreement Procedures (Japanese) [PDF]
, 2010 Mutual agreement procedures refer to an international tax dispute resolution mechanism, in which tax authorities of countries party to bilateral tax conventions (or treaties) negotiate. In recent years, the importance of the mutual agreement procedures has been growing, as the number of cases in which taxpayers request that their governments initiate ...
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Procedural Guarantees of Taxpayers in International Mutual Agreement Procedures
Rossijskoe Pravo. Obrazovanie, Praktika, Nauka, 2021openaire +1 more source
Chapter 7: Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law
2020H. Jirousek, A. Streicher
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