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The Mutual Agreement Procedure In International Taxation
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Book Synopsis The Mutual Agreement Procedure in International Taxation by : Juliane Gröper
Download or read book The Mutual Agreement Procedure in International Taxation written by Juliane Gröper and published by utzverlag GmbH. This book was released on 2020-02-19 with total page 246 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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. Therefore, measures are needed to avoid international double taxation. The number of international Mutual Agreement Procedures is rising accordingly. However, the Mutual Agreement Procedure is not always effective and is often evaded by developing countries in particular. According to the author, the deficits of the Mutual Agreement Procedure should be mitigated by procedural and administrative rules. These can be based on experiences gained from other areas of law with cross-border economic activities. Moreover, the use of modern technologies or non-binding dispute resolution mechanisms can enhance the efficiency of the Mutual Agreement Procedure. The procedural and administrative rules should not only make the procedure more attractive for states and especially developing countries but also improve the position of the taxpayer.
Book Synopsis Interpretation and Application of Tax Treaties in North America by : Juan Angel Becerra
Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Book Synopsis Multilateral Tax Treaties by : Helmut Loukota
Download or read book Multilateral Tax Treaties written by Helmut Loukota and published by Kluwer Law International B.V.. This book was released on 1998-04-22 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is a result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed analysis of the arguments for and against the conclusion of a multilateral tax treaty, and of the various European law issues that arise in this context.
Book Synopsis Research Handbook on International Taxation by : Yariv Brauner
Download or read book Research Handbook on International Taxation written by Yariv Brauner and published by Edward Elgar Publishing. This book was released on 2020-12-25 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Book Synopsis Transfer Pricing and Dispute Resolution by : Anuschka Bakker
Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
Book Synopsis A Global Analysis of Tax Treaty Disputes by : Eduardo Baistrocchi
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Book Synopsis Arbitration Under Tax Treaties by : Mario Züger
Download or read book Arbitration Under Tax Treaties written by Mario Züger and published by IBFD. This book was released on 2001 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of both the concluded and the proposed dispute resolution methods. The relationship between the current developments in tax treaty law and the more general trends of modern dispute resolution in public international law is investigated. Concludes with a summary and evaluation of several alternative methods of dispute resolution in recent treaty practice.
Book Synopsis Shaping an International Tax Order by :
Download or read book Shaping an International Tax Order written by and published by Institute of Legal Studies Kansai University. This book was released on 1996 with total page 220 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proceedings of a symposium, organized by the Institute of Legal Studies, held on 27 and 28 July 1994 at Kansai University. Symposium 1: Tax treaty override; Symposium 2: Procedural aspects of transfer pricing relief.
Book Synopsis Dispute Resolution Under Tax Treaties by : Zvi Daniel Altman
Download or read book Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and published by IBFD. This book was released on 2005 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
Book Synopsis Switzerland in International Tax Law by : Xavier Oberson
Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Book Synopsis Tax Polymath - A life in International Taxation by :
Download or read book Tax Polymath - A life in International Taxation written by and published by IBFD. This book was released on 2010 with total page 425 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book comprises a selection of papers presented at a conference in honour of John Avery Jones which was held on 22 and 23 April 2010 in London.
Book Synopsis Introduction to the Law of Double Taxation Conventions by : Michael Lang
Download or read book Introduction to the Law of Double Taxation Conventions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2021-04-01 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Book Synopsis United States Tax Treaties by : United States
Download or read book United States Tax Treaties written by United States and published by Springer. This book was released on 1991-02-05 with total page 678 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.
Book Synopsis OECD Arbitration in Tax Treaty Law by : Alicja Majdanska
Download or read book OECD Arbitration in Tax Treaty Law written by Alicja Majdanska and published by Linde Verlag GmbH. This book was released on 2018-09-14 with total page 768 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes.
Book Synopsis Tax Treaty Dispute Resolution by : Rachna Matabudul
Download or read book Tax Treaty Dispute Resolution written by Rachna Matabudul and published by Kluwer Law International B.V.. This book was released on 2023-11-07 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: Stakeholders in the international taxation community agree that existing dispute resolution processes are in serious need of improvement, and a global consensus must be achieved. This book offers a potential restructuring of the tax treaty dispute resolution system based on a comparative analysis of the dispute resolution mechanisms under tax treaties, as prescribed in the OECD and UN models, on the one hand, and the UN Law of the Sea Convention (LOSC) on the other. This comparative study is the first of its kind and is premised on certain key geopolitical similarities that underpin the international tax regime (ITR) and the law of the sea regime while taking into consideration the differences in the institutional context of both regimes. The author proposes a new tax treaty dispute resolution system based on the LOSC system for resolving multilateral tax disputes, focusing on the following: mapping of the institutional arrangements that make up the dispute resolution mechanisms to understand how each system works; comparative analysis of the patterns of interaction and outcomes generated across the two dispute resolution systems to identify relevant aspects of the LOSC system that may be adapted in the ITR to improve tax treaty dispute resolution; and analysis of the inclusivity levels across the decision-making structures under each system to identify specific consensus-building techniques that may facilitate the implementation of the new proposed tax treaty dispute resolution system and also enhance international cooperation across the ITR. The proposed restructuring of the tax treaty dispute resolution system expands the existing mutual agreement procedure and forms a comprehensive legal framework that aims to achieve a more effective, predictable and equitable resolution of multilateral tax disputes in the 21st-century ITR by striking a balance between countries’ right to tax sovereignty and the rule of law. Just as the design of the dispute resolution system under the LOSC paved the way for universal consensus of the Convention among almost 160 countries, the author’s new tax treaty dispute resolution system also offers a solid foundation for consensus-building towards a universal treaty in the ITR. Everyone concerned with international tax dispute resolution – whether policymaker, in-house counsel, national tax authority official, judge, tax lawyer or academic – will find the truly valuable analysis here, not elsewhere.
Book Synopsis Federal Income Tax Project by : American Law Institute
Download or read book Federal Income Tax Project written by American Law Institute and published by . This book was released on 1992 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proposals on United States income tax treaties. The book is a companion volume to "International aspects of United States income taxation" published in 1987. While the 1987 volume addressed various aspects of US internal income tax law as applied to international transactions, this volume deals with the special set of problems involved in treaties between the US and their trading partners by which it is sought to bring divergent national tax laws and incidents of taxation into reasonable accord.
