Results 241 to 250 of about 3,896,139 (291)

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).
exaly   +2 more sources

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.
exaly   +2 more sources

Mutual Agreement Procedure: la Convenzione arbitrale europea sul Transfer Pricing

, 2012
I recenti chiarimenti sulle procedure amichevoli per dirimere le controversie internazionali hanno specificamente approfondito la Mutual Agreement Procedure prevista dalla Convenzione arbitrale con riguardo ai casi di doppia imposizione derivanti da rettifiche sui prezzi di trasferimento che coinvolgano imprese di Stati membri dell’Unione europea ...
GARBARINO, CARLO, G. Comi
openaire   +2 more sources

The Relationship Between the Mutual Agreement Procedure and Internal Law

EC Tax Review, 1999
exaly   +2 more sources

Related Party Concept, Transfer Pricing Correction Disputes, Mutual Agreement Procedure (MAP) Submission: Indonesia Case

Riset, 2022
This research aimed to determine the concept of related parties between countries as the entry point for resolving the dispute over Transfer Pricing (TP) through Mutual Agreement Procedure (MAP).
Firmansyah, Amrie, Ilham, Muhammad, Widiastuti, Budiasih, Muhammad Ilham, Amrie Firmansyah, Budiasih Widiastuti   +5 more
exaly   +2 more sources

VIII. Mutual Agreement and Arbitration Procedures (2006)

2012
exaly   +2 more sources

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. van der Klok, T. Elshof
openaire   +1 more source

The Revised Mutual Agreement Procedure and Recent Developments in Turkey

European Taxation, 2022
Turkey has enacted new Mutual Agreement Procedure (MAP) regulations (Law 7338 of 14 October 2021) in an effort to facilitate the resolution of international tax disputes, improve legal certainty and conform to the minimum standard of Action 14 of the OECD/G20 BEPS Project.
openaire   +1 more source

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.
openaire   +1 more source

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 ...
openaire   +1 more source