Results 271 to 280 of about 672,642 (313)

Strengthening legal certainty and transparency in the mutual agreement procedure in Switzerland

2020
Matteotti, René, Bieri, Monika
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Transfer Pricing and Mutual Agreement Procedures

International Transfer Pricing Journal, 2009
The 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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ECJ and Mutual Agreement Procedures

Intertax, 2014
The 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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TAX DISPUTE RESOLUTION MECHANISM IN THE EUROPEAN UNION OR MUTUAL AGREEMENT PROCEDURE TO AVOID DOUBLE TAXATION?

European Financial Resilience and Regulation
This paper aims to clarify how the provisions of Council Directive (EU) 2017/1852 on tax dispute resolution mechanisms in the European Union should be understood and applied. This directive is supplemented by the provisions of its Implementing Regulation
Cristina Onet
semanticscholar   +1 more source

TYPES OF TAX BEHAVIOR AND THEIR DISTINCTIVE FEATURES AS A CRITERION FOR THE ADMISSIBILITY OF THE APPLICATION OF THE MUTUAL AGREEMENT PROCEDURE IN THE FRAMEWORK OF TAX CONVENTIONS

Bulletin of Institute of Legislation and Legal Information of the Republic of Kazakhstan
In the article the author examines the types of tax behavior and their peculiarities as the main criterion of admissibility of application of international legal mechanisms of settlement of international tax disputes, in particular, the Mutual Agreement ...
Тomiris Sailauovna Smagulova
semanticscholar   +1 more source

A Theoretical Reflection on the OECD’s New Statistics Reporting Framework for the Mutual Agreement Procedure: Isolating, Measuring, and Monitoring

Journal of international economic law, 2018
In October 2015, the G20 Finance Ministers endorsed the base erosion and profit shifting (BEPS) project, which has been acclaimed as the most fundamental transformation of the international tax rules in almost a century.
Q. Cai, Pengfei Zhang
semanticscholar   +1 more source

Factors Militating against the Efficacy of the Mutual Agreement Procedure: A Comparison between South Africa, Kenya, Uganda and Ghana

Comparative and International Law Journal of Southern Africa
The effective resolution of transfer pricing disputes has been identified as one of the primary challenges to eliminate double taxation and/or double non-taxation as well as to enhance the free flow of trade and investment.
Nelson Kekana
semanticscholar   +1 more source

International tax dispute resolution through mutual agreement procedure in Indonesia: Past, present, and future

Educoretax
Mutual Agreement Procedure (MAP) is widely recognized as an international tax dispute resolution mechanism to resolve double taxation among jurisdictions, generally governed under Article 25 of double taxation agreements.
Defi Defi
semanticscholar   +1 more source

Mutual agreement procedure and the right of access to justice an analysis of the Colombian regulation

2023
El Procedimiento de Mutuo Acuerdo es un mecanismo para la resolución de controversias en los Convenios de Doble Imposición, introducido en Colombia a través de los Convenios de Doble Imposición suscritos por el Estado. Este procedimiento ha sido desarrollado a través de la regulación colombiana del Procedimiento de Mutuo Acuerdo, prevista en el ...
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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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