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The mutual agreement procedure and arbitration of double taxation disputes
It is in the interest of most states to eliminate double taxation (i.e. the payment of the same tax in two jurisdictions) oftransnational commercial enterprises.
Ilias Bantekas
doaj +3 more sources
A Legal Analysis of the Structure of Dispute Resolution Mechanisms of International Tax Agreements [PDF]
As international trade is expanding, international trade and tax disputes are increasing. Under international tax agreements, there are two mechanisms for the resolution of potential disputes between contracting States.
Alireza Salehifar
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BEPS 2.0 Pillar I solutions on mechanisms of tax dispute resolutions
The purpose of the article is to present the basic assumptions of Pillar I of BEPS 2.0 and to identify areas of potential disputes on the background of the application of the new mechanisms. The article will briefly outline preventive mechanisms aimed at
Małgorzata Duda-Plesińska
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Legal nature of the agreement on the use of security measures in relation to criminal proceeding participants [PDF]
The relevance of the study is due to the presence of a set of theoretical and practical issues and gaps in the legal regulation of the agreement concluded with the protected person on the conditions of security measures, mutual obligations, and ...
Grigoryeva Natalia Vladimirovna +3 more
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Resolution of dual residence instances in the case of companies [PDF]
The application of double taxation treaties presupposes that the potential cases of dual residence have been previously resolved. For this purpose, the major model-conventions on the basis of which double taxation treaties around the globe are negotiated
Živković Lidija
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Mutual Unbiasedness in Coarse-grained Continuous Variables [PDF]
The notion of mutual unbiasedness for coarse-grained measurements of quantum continuous variable systems is considered. It is shown that while the procedure of "standard" coarse graining breaks the mutual unbiasedness between conjugate variables, this ...
Erdmann, Kati +7 more
core +6 more sources
Penelitian ini bertujuan untuk mengetahui apa sebenarnya permasalahan mendasar yang dihadapi dalam penyelesaian sengketa koreksi Transfer Pricing (TP) melalui MAP di Indonesia.
Muhammad Ilham, Budiasih Widiastuti
semanticscholar +1 more source
Abstrak Praktek Abuse of Transfer Pricing dalam tansaksi bisnis antar Perusahaan Multinasional yang memiliki hubungan istimewa sangat merugikan negara terutama dalam penarikan pajak.
Mega Indah Permatasari +1 more
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The Questionable Polish-German Pandemic Mutual Agreement
The outbreak of the coronavirus (COVID-19) pandemic in 2020 prompted countries around the world to take countermeasures. One was to restrict the movement of citizens between countries for employment purposes amongst others.
Błażej Kuźniacki, Wojciech Morawski
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Arbitrability of International Tax Disputes [PDF]
Over the past years, "arbitration" as a means of settling international disputes has gained popularity, but compared to international tax disputes, the possibility of applying the arbitration clause is disputed. After the successful use of arbitration to
Naeem Noorbakhsh +2 more
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