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International tax disputes resolution through the mutual agreements and arbitration procedures

, 2009
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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.
©. IbFD, M. Markham
exaly   +3 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).
Z. Adam
exaly   +3 more sources

Mutual Agreement Procedure

Tax Treaty Networks 1991, 2021
John S. Phillips
exaly   +5 more sources

Solving Double Taxation outside the Realm of a Mutual Agreement Procedure

International Transfer Pricing Journal, 2019
As transfer pricing adjustments are expected to increase, so will be mutual agreement procedure requests in order to remedy the resulting double taxation. To forego the downsides of this procedure, this article suggests that a MAP should be preceded by an attempt to obtain an unilateral corresponding adjustment.
E. Vroemen
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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
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Mutual Agreement Procedure: Preventing the Compulsory Jurisdiction of the International Court of Justice?

Intertax, 2009
This article analyses whether the presence of the Mutual Agreement Procedure (MAP) in tax treaties can prevent the compulsory jurisdiction of the International Court of Justice (ICJ) in disputes in which the States involved have signed the optional clause with reservations ratione fori.
Luciana Nobrega e Silva Loureiro
exaly   +3 more sources

The Revised Mutual Agreement Procedure and Recent Developments in Turkey

European Taxation, 2022
Turkey 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.
M. Kara
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Mutual Agreement Procedure and Foreign Direct Investments: Evidence from Firm-level Data

SSRN Electronic Journal, 2023
This 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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