Results 281 to 290 of about 672,642 (313)

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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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 ...
openaire  

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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The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures

Journal of International Accounting, Auditing and Taxation, 2008
Abstract In its 25 years of existence, the Pacific Association of Tax Administrators (PATA) has attempted to protect tax revenues and combat tax evasion techniques (including transfer pricing) by transnational corporations (TNCs). To that end, the tax authorities of its four member countries (Australia, Canada, Japan and the United States) have met ...
openaire   +2 more sources

Procedural Guarantees of Taxpayers in International Mutual Agreement Procedures

Rossijskoe Pravo. Obrazovanie, Praktika, Nauka, 2021
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Chapter 7: Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law

2020
H. Jirousek, A. Streicher
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International tax treaty dispute resolution, the mutual agreement procedure, and the promise of mandatory arbitration for developing countries

, 2020
Y. Brauner
semanticscholar   +1 more source

Mutual authentication quantum key agreement protocol based on Bell states

Quantum Information Processing, 2022
Yefeng He
exaly  

Transfer Pricing, Corresponding Adjustments and the Mutual Agreement Procedure

Model Tax Convention on Income and on Capital (Full Version), 2019

semanticscholar   +1 more source

Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law

2020
Jirousek, Heinz, Streicher, Annika
openaire   +1 more source