ZT-RIASE: Zero Trust-resilient identity attestation for securing smart industrial IoT environment. [PDF]
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Pathways to Agency: Cross-Cultural Evidence From Indigenous Wichi and Eurodescendant Caregiver-Infant Interactions. [PDF]
Padilla Colón MI, Taverna AS, Waxman S.
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Temporal speckle enables probabilistic weights for uncertainty-aware photonic AI
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International tax disputes resolution through the mutual agreements and arbitration procedures
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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 Timely Resolution of Mutual Agreement Procedure Disputes – Secrets of Success?
Bulletin for International Taxation, 2023In 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.
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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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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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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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