Results 201 to 210 of about 227,095 (228)
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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
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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
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Mutual Agreement Procedure Arbitration in Developing Countries – The ASEAN Experience
Bulletin for International Taxation, 2016This 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).
Z. Adam
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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
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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
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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
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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
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Article: Improving the Relationship Between Tax Authorities and Taxpayers in Brazil
Intertax, 2022Brazilian tax authorities have traditionally had an adversarial relationship with taxpayers. Recent initiatives, however, show a paradigm shift that may bring taxpayers and tax authorities together.
Phelippe Toledo Pires de Oliveira
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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
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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
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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
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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
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Tax Code Provisions on the Specific Case Mutual Agreement Procedure: A Commentary
European TaxationArticle 108-1 of the Tax Code of Ukraine, added in January 2020, establishes specific rules regarding the mutual agreement procedure (MAP). In this note, the author analyses the personal scope of MAPs under article 108-1, as well as some substantive and ...
P. Selezen
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Mandatory Binding Arbitration: Avoiding Stalemates Over the Tax Chessboard
Intertax, 2021The resolution of tax treaty disputes under the Mutual Agreement Procedure (MAP) mechanism is inherently problematic. This article examines how the introduction of final-offer arbitration (FOA) can improve dispute resolution using a game-theoretical ...
Polyvios Nikolaou
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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 ...
Luciana Nobrega e Silva Loureiro
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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 ...
Luciana Nobrega e Silva Loureiro
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