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The Mutual Agreement Procedure in International Taxation

2020
The 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.
Juliane Gröper
openaire   +2 more sources

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.
B. Hassan
exaly   +2 more sources

A Package Deal Is Not a Bad Deal: Reassessing the Method of Package Negotiation Under the Mutual Agreement Procedure

Intertax, 2018
Traditionally, most international tax disputes among jurisdictions have been resolved through the mechanism of the mutual agreement procedure (MAP). A long-standing concern with MAPs is that competent authorities might pursue a so-called package deal ...
Q. Cai
exaly   +2 more sources

Is the Mutual Agreement Procedure Past Its “Best-Before Date” and Does the Future of Tax Dispute Resolution Lie in Mediation and Arbitration?

Bulletin for International Taxation, 2014
This article examines dispute resolution mechanisms under tax treaties and bilateral investment agreements, with a particular focus on mutual agreement procedure (MAP).
Poonam Khaira Sidhu
exaly   +2 more sources

Seeking New Directions in Dispute Resolution Mechanisms: Do We Need a Revised Mutual Agreement Procedure?

Bulletin for International Taxation, 2016
This article examines issues in reforming the mutual agreement procedure (MAP), drawing on concerns raised by various organizations, especially the OECD. It evaluates perceived obstacles to the functioning of this aspect of the global tax environment and
M. Markham
exaly   +2 more sources

Tax Code Provisions on the Specific Case Mutual Agreement Procedure: A Commentary

European Taxation
Article 108-1 of the Tax Code of Ukraine, added in January 2020, establishes specific rules regarding the mutual agreement procedure (MAP). In this note, the author analyses the personal scope of MAPs under article 108-1, as well as some substantive and procedural features.
P. Selezen
openaire   +2 more sources

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 ...
exaly   +2 more sources

Making the Mutual Agreement Procedure More Effective in Greece: A Commentary on the Guidelines for the Conduct of MAPs

European Taxation, 2021
In October 2020, the Greek Independent Authority for Public Revenue published a new decision, Decision A. 1226/2020, amending the guidelines for the conduct of the mutual agreement procedure (MAP) under tax treaties. The amendments were necessary in view
K. Perrou
semanticscholar   +1 more source

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