Results 211 to 220 of about 38,109 (257)

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.
exaly   +2 more sources

The relationship between the mutual agreement procedure and internal law

EC Tax Review, 1999
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
openaire   +1 more source

The Revised Mutual Agreement Procedure and Recent Developments in Turkey

European Taxation, 2022
Turkey 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.
openaire   +1 more source

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.
openaire   +1 more source

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

New Spanish regulation on the mutual agreement procedure

Bulletin for International Taxation, 2009
In 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 ...
openaire   +1 more source

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.
openaire   +1 more source

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 ...
openaire   +1 more source

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