Results 211 to 220 of about 37,178 (259)

The Mutual Agreement Procedure

2023
exaly   +2 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
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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 ...
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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.
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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

Can the Brazilian Mutual Agreement Procedure Legislation Be Effective Domestically?

Bulletin for International Taxation, 2019
This 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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Solving Double Taxation outside the Realm of a Mutual Agreement Procedure

International Transfer Pricing Journal, 2019
As 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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Mutual agreement procedure and the right of access to justice an analysis of the Colombian regulation

2023
El Procedimiento de Mutuo Acuerdo es un mecanismo para la resolución de controversias en los Convenios de Doble Imposición, introducido en Colombia a través de los Convenios de Doble Imposición suscritos por el Estado. Este procedimiento ha sido desarrollado a través de la regulación colombiana del Procedimiento de Mutuo Acuerdo, prevista en el ...
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Status of Interpretative Mutual Agreement Procedures: Case Study

European Taxation
In 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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Mutual Agreement Procedure

2016
The contribution deals with issues related to the procedure for submitting the application for a mutual agreement procedure, the consequent critical issues and the effects on the tax ...
openaire   +1 more source