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International tax disputes resolution through the mutual agreements and arbitration procedures
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The Timely Resolution of Mutual Agreement Procedure Disputes – Secrets of Success?
Bulletin 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
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The Revised Mutual Agreement Procedure and Recent Developments in Turkey
European Taxation, 2022Turkey 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.
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New Spanish regulation on the mutual agreement procedure
Bulletin for International Taxation, 2009In 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 ...
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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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Transfer Pricing and Mutual Agreement Procedures
International Transfer Pricing Journal, 2009The 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
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ECJ and Mutual Agreement Procedures
Intertax, 2014The 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 ...
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The Mutual Agreement Procedure in International Taxation
2020The 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.
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