Results 261 to 270 of about 526,426 (311)

New Spanish regulation on the mutual agreement procedure

Bulletin for International Taxation, 2009
In November 2008, Spain issued a new regulation on the mutual agreement procedure (MAP)which applies to two procedures: the MAP under Spain's tax treaties and the procedure governed by the EC Arbitration Convention. This article examines and analyses the new regulation, including (among other things) its scope and structure, its common provisions, the ...
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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).
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Saudi Arabia Issues Taxpayers Guidance Concerning Mutual Agreement Procedure under Tax Treaties

International Transfer Pricing Journal, 2020
On 16 June 2020, Saudi Arabia issued taxpayers guidance for a mutual agreement procedure (MAP) to be used for the resolution of disputes under bilateral tax treaties. Based on the guidance, this article describes the MAP, the conditions and procedure, the process and deadlines for its completion and the implementation of the MAP outcome.
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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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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.
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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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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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Mutual Agreement Procedure

2021
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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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