Results 251 to 260 of about 3,896,139 (291)

Can the Brazilian Mutual Agreement Procedure Legislation Be Effective Domestically?

Bulletin for International Taxation, 2019
This article examines the new Brazilian legislation in respect of mutual agreement procedures in light of the changes proposed by Action 14 of the OECD/G20 BEPS initiative and considers whether such legislation can be effective in the country.
D. Canen, H. de Conti
openaire   +1 more source

Mutual Agreement Procedure and Foreign Direct Investments: Evidence from Firm-level Data

International Tax and Public Finance, 2023
This paper investigates the association between the effectiveness of mutual agreement procedures provided for in bilateral tax treaties (MAP) and foreign direct investments by analyzing MAP statistics and distinct MAP components. Using firm-level ownership data, we find that MNEs invest more frequently in countries with good MAP policy structures and ...
Petutschnig, Matthias, Zhang, Xixi
openaire   +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

Solving Double Taxation outside the Realm of a Mutual Agreement Procedure

International Transfer Pricing Journal, 2019
As transfer pricing adjustments are expected to increase, so will be mutual agreement procedure requests in order to remedy the resulting double taxation. To forego the downsides of this procedure, this article suggests that a MAP should be preceded by an attempt to obtain an unilateral corresponding adjustment.
openaire   +1 more source

Using Mutual Agreement Procedures to Create a Proxy for Bilateral Tax Controversy

2018
This is a methodical note. We aim to develop a technique to estimate joint frequencies from marginal frequencies in a contingency table of interactions between two parties. We apply this technique to the practical setting of the OECD statistics on mutual agreement procedures between countries where only marginal frequencies, i.e.
Matthias Eckerle, Mark M. Trede, Robert Ullmann   +2 more
openaire   +1 more source

Mutual Agreement Procedure: Preventing the Compulsory Jurisdiction of the International Court of Justice?

Intertax, 2009
This article analyses whether the presence of the Mutual Agreement Procedure (MAP) in tax treaties can prevent the compulsory jurisdiction of the International Court of Justice (ICJ) in disputes in which the States involved have signed the optional clause with reservations ratione fori.
openaire   +1 more source

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  

Mutual Agreement Procedure

2021
openaire   +3 more sources

Procedural Guarantees of Taxpayers in International Mutual Agreement Procedures

Rossijskoe Pravo. Obrazovanie, Praktika, Nauka, 2021
openaire   +1 more source

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.
openaire   +1 more source