Results 201 to 210 of about 38,109 (257)

Temporal speckle enables probabilistic weights for uncertainty-aware photonic AI

open access: yes
Pernice W   +14 more
europepmc   +1 more source

ECJ and Mutual Agreement Procedures

Intertax, 2014
The Mutual Agreement Procedure (Article 25 OECD Model Convention) is a rather helpful tool to sort out all kind of interpretation conflicts between two contracting states. If tax treaties are in an intra-Union setting replaced by a Directive and if the content of the OECD Model Convention is transformed in such a Directive, the Court of Justice would ...
exaly   +3 more sources

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.
exaly   +2 more sources

Can the Brazilian Mutual Agreement Procedure Legislation Be Effective Domestically?

Bulletin for International Taxation, 2019
This article examines the new Brazilian legislation in respect of mutual agreement procedures in light of the changes proposed by Action 14 of the OECD/G20 BEPS initiative and considers whether such legislation can be effective in the country.
D. Canen, H.de Conti
exaly   +2 more sources

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

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.
exaly   +2 more sources

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