Results 221 to 230 of about 38,109 (257)
Some of the next articles are maybe not open access.
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.
openaire +1 more source
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.
openaire +1 more source
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 ...
openaire
Procedural Guarantees of Taxpayers in International Mutual Agreement Procedures
Rossijskoe Pravo. Obrazovanie, Praktika, Nauka, 2021openaire +1 more source
Chapter 7: Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law
2020H. Jirousek, A. Streicher
openaire +1 more source
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 ...
openaire +1 more source
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 ...
openaire +1 more source
The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures
Journal of International Accounting, Auditing and Taxation, 2008Abstract 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 ...
openaire +2 more sources
Tax Code Provisions on the Specific Case Mutual Agreement Procedure: A Commentary
European TaxationArticle 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.
openaire +1 more source
Mutual authentication quantum key agreement protocol based on Bell states
Quantum Information Processing, 2022Yefeng He
exaly