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International tax disputes resolution through the mutual agreements and arbitration procedures
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An Improved Pipeline for Constructing UK Biobank Brain Imaging Confounds
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Transfer Pricing and Mutual Agreement Procedures
International Transfer Pricing Journal, 2009The recently issued Decree on the Mutual Agreement Procedure and the inclusion of a revised arbitration clause in the new tax treaty with the United Kingdom clearly demonstrate the importance given by the Netherlands to solving transfer pricing discussions.
B.vander Klok, T. Elshof
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Mutual Agreement Procedure and Foreign Direct Investments: Evidence from Firm-level Data
SSRN Electronic Journal, 2023This paper investigates the association between the effectiveness of mutual agreement procedures provided for in bilateral tax treaties (MAP) and foreign direct investments by analyzing MAP statistics and distinct MAP components. Using firm-level ownership data, we find that MNEs invest more frequently in countries with good MAP policy structures and ...
Petutschnig, Matthias, Zhang, Xixi
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ECJ and Mutual Agreement Procedures
Intertax, 2014The 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 ...
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The Revised Mutual Agreement Procedure and Recent Developments in Turkey
European Taxation, 2022Turkey has enacted new Mutual Agreement Procedure (MAP) regulations (Law 7338 of 14 October 2021) in an effort to facilitate the resolution of international tax disputes, improve legal certainty and conform to the minimum standard of Action 14 of the OECD/G20 BEPS Project.
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The Mutual Agreement Procedure in International Taxation
2020The globalization of economic and multinational business structures has exacerbated the problem of substantive overlapping national tax laws in recent decades. Double taxation has a negative impact on international economic transactions because it leads to the suboptimal allocation of capital and affects the cross-border exchange of goods.
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Can the Brazilian Mutual Agreement Procedure Legislation Be Effective Domestically?
Bulletin for International Taxation, 2019This 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
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The Timely Resolution of Mutual Agreement Procedure Disputes – Secrets of Success?
Bulletin for International Taxation, 2023In 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.
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