Results 221 to 230 of about 36,811 (255)

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 ...
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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

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 ...
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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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Procedural Guarantees of Taxpayers in International Mutual Agreement Procedures

Rossijskoe Pravo. Obrazovanie, Praktika, Nauka, 2021
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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.
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The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures

Journal of International Accounting, Auditing and Taxation, 2008
Abstract 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 ...
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Chapter 7: Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law

2020
H. Jirousek, A. Streicher
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Tax Code Provisions on the Specific Case Mutual Agreement Procedure: A Commentary

European Taxation
Article 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.
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Mutual authentication quantum key agreement protocol based on Bell states

Quantum Information Processing, 2022
Yefeng He
exaly