Results 211 to 220 of about 3,784,238 (242)

The Effectiveness of Mutual Agreement Procedures as a Means for Settling International Transfer Pricing Disputes

International Transfer Pricing Journal, 2014
This article addresses the current status quo of the mutual agreement procedure, tackling the various issues related to article 25 of the OECD Model Convention and the EU Arbitration Convention (90/436). Certain obstacles to a proper functioning of the MAP are also addressed, including the underlying reasons of why the MAP has been an ineffective ...
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The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures

Journal of International Accounting, Auditing and Taxation, 2008
Abstract In its 25 years of existence, the Pacific Association of Tax Administrators (PATA) has attempted to protect tax revenues and combat tax evasion techniques (including transfer pricing) by transnational corporations (TNCs). To that end, the tax authorities of its four member countries (Australia, Canada, Japan and the United States) have met ...
openaire   +2 more sources

The Mutual Agreement Procedure

2023
openaire   +1 more source

Tax Code Provisions on the Specific Case Mutual Agreement Procedure: A Commentary

European Taxation
Article 108-1 of the Tax Code of Ukraine, added in January 2020, establishes specific rules regarding the mutual agreement procedure (MAP). In this note, the author analyses the personal scope of MAPs under article 108-1, as well as some substantive and procedural features.
openaire   +1 more source

Mutual authentication quantum key agreement protocol based on Bell states

Quantum Information Processing, 2022
Yefeng He
exaly  

Strengthening legal certainty and transparency in the mutual agreement procedure in Switzerland

2020
Matteotti, René, Bieri, Monika
openaire   +1 more source

Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law

2020
Jirousek, Heinz, Streicher, Annika
openaire   +1 more source

An ID-based remote mutual authentication with key agreement scheme for mobile devices on elliptic curve cryptosystem

Computers and Security, 2009
Chin-Chen Chang
exaly  

Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

OECD/G20 Base Erosion and Profit Shifting Project, 2023
exaly  

Using Mutual Agreement Procedures to Create a Proxy for Bilateral Tax Controversy

SSRN Electronic Journal, 2018
Matthias Eckerle, Mark M. Trede, Robert Ullmann   +2 more
openaire   +1 more source