Results 211 to 220 of about 227,095 (228)

Modern International Tax Dispute Resolution – An African Perspective on the Mutual Agreement Procedure, Arbitration, and the Future

Intertax
This article contributes to the literature by questioning the efficacy of the MAP for the resolution of international tax disputes from a developing country perspective.
Gabriel Aliu
semanticscholar   +1 more source

Mutual Agreement Procedures in Tax Treaties: Problems and Needs in Developing Countries and Countries in Transition

Intertax, 2014
Mutual agreement procedure is a key tool that need to be strengthened in order to reduce unresolved treaty-related disputes, while providing certainty and predictability for business.
C. Protto
semanticscholar   +1 more source

The Effectiveness of Mutual Agreement Procedures as a Means for Settling International Transfer Pricing Disputes

International Transfer Pricing Journal, 2014
This article addresses the current status quo of the mutual agreement procedure, tackling the various issues related to article 25 of the OECD Model Convention and the EU Arbitration Convention (90/436).
R. Bicer
semanticscholar   +1 more source

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.
M. Lang
semanticscholar   +1 more source

The Ombudsman and the Process of Resolution of International Tax Disputes – Protecting the “Invisible Party” to the MAP

World Tax Journal, 2017
This article explores the possible involvement of tax specialist ombudsmen in the mutual agreement procedure (MAP). With the current level of development of the MAP still facing criticism for a lack of efficiency and transparency, and the arbitration ...
K. Perrou
semanticscholar   +1 more source

The MAP in Greece: New Domestic Procedural Framework Enhances Effectiveness of Cross-Border Dispute Resolution

European Taxation, 2017
This article outlines the recently established framework for the mutual agreement procedure under the Greek Tax Procedure Code, including an analysis of certain legal issues arising from its application.
L. Sofrona
semanticscholar   +1 more source

MAP Guidance Released by the Revenue Service

International Transfer Pricing Journal, 2017
On 10 November 2016, the Brazilian Revenue Service issued guidance on the mutual agreement procedure in tax treaties. The ruling put an end to years of uncertainty and provided transparency to taxpayers, but it set conditions that deviate from treaties ...
L.E. Schoueri, M. Barbosa
semanticscholar   +1 more source

Annex II to Chapter IV. Guidelines for conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)

, 2022

semanticscholar   +1 more source

Applying Modern, Disruptive Technologies to Improve the Effectiveness of Tax Treaty Dispute Resolution: Part 1

Intertax, 2018
This comprehensive two-part article addresses how modern, disruptive technologies can be used to improve the effectiveness of tax treaty dispute resolution. It is clear that international tax dispute resolution needs improvement.
Laura Turcan, Sriram Govind, Christina Dimitropoulou   +2 more
semanticscholar   +1 more source

Place of Effective Management as a Treaty Tie-breaker Rule: Historical Evolution, Challenges, and Future Perspectives

Intertax
This article revisits the place of effective management (POEM) as a treaty tie-breaker rule for resolving cases of dual corporate tax residence under double tax treaties.
M. Hemdan, K. Tetłak
semanticscholar   +1 more source