Results 231 to 240 of about 182,633 (276)

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 ...
openaire   +2 more sources

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

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

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
semanticscholar   +1 more source

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
semanticscholar   +1 more source

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
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 ...
openaire   +1 more source

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.
openaire   +1 more source

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 ...
openaire   +1 more source