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Several Issues regarding the Mutual Agreement Procedures (Japanese) [PDF]

open access: possible, 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  

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.
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, 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 ...
openaire   +2 more sources

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
openaire   +1 more source

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