Results 221 to 230 of about 37,178 (259)

Mutual Agreement Procedure: Preventing the Compulsory Jurisdiction of the International Court of Justice?

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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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, 2021
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Transfer Pricing Dispute Resolution and Mutual Agreement Procedures: An Indonesian Perspective

International Transfer Pricing Journal, 2017
This 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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Chapter 7: Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law

2020
H. Jirousek, A. Streicher
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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 ...
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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.
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Mutual Agreement Procedure: la Convenzione arbitrale europea sul Transfer Pricing

2012
I recenti chiarimenti sulle procedure amichevoli per dirimere le controversie internazionali hanno specificamente approfondito la Mutual Agreement Procedure prevista dalla Convenzione arbitrale con riguardo ai casi di doppia imposizione derivanti da rettifiche sui prezzi di trasferimento che coinvolgano imprese di Stati membri dell’Unione europea ...
GARBARINO, CARLO, G. Comi
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Strengthening legal certainty and transparency in the mutual agreement procedure in Switzerland

2020
Matteotti, René, Bieri, Monika
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