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The Timely Resolution of Mutual Agreement Procedure Disputes – Secrets of Success?

Bulletin for International Taxation, 2023
In 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.
Markham, Michelle
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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 ...
exaly   +2 more sources

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 ...
Quattrocchi A
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Mutual Agreement Procedure Arbitration in Developing Countries – The ASEAN Experience

Bulletin for International Taxation, 2016
This 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).
exaly   +2 more sources

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: 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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Seeking New Directions in Dispute Resolution Mechanisms: Do We Need a Revised Mutual Agreement Procedure?

, 2016
This article examines issues in reforming the mutual agreement procedure (MAP), drawing on concerns raised by various organizations, especially the OECD. It evaluates perceived obstacles to the functioning of this aspect of the global tax environment and
Markham, Michelle
exaly   +3 more sources

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: 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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