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Author: Publisher: ISBN: Category : Languages : en Pages : 32
Book Description
This discussion paper suggests that EU members should consider a number of ways to settle cross-border transfer pricing disputes before they reach taxpayers, including consultations on audits and reassessments and establishing a model European advance pricing agreement to expedite bilateral APAs. It also suggests that member state tax authorities establish a model APA, thereby creating uniform EU APA requirements, consult one another before launching a transfer pricing audit, consider mutually agreed transfer pricing reassessments, and use mediation to hasten and streamline dispute resolution.
Author: Publisher: ISBN: Category : Languages : en Pages : 32
Book Description
This discussion paper suggests that EU members should consider a number of ways to settle cross-border transfer pricing disputes before they reach taxpayers, including consultations on audits and reassessments and establishing a model European advance pricing agreement to expedite bilateral APAs. It also suggests that member state tax authorities establish a model APA, thereby creating uniform EU APA requirements, consult one another before launching a transfer pricing audit, consider mutually agreed transfer pricing reassessments, and use mediation to hasten and streamline dispute resolution.
Author: Eduardo Baistrocchi Publisher: Cambridge University Press ISBN: 1108150381 Category : Law Languages : en Pages : 2216
Book Description
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.
Author: Pablo Cortés Publisher: Routledge ISBN: 1136943501 Category : Law Languages : en Pages : 283
Book Description
Offers an account of ODR for consumers in the EU context, presenting a comprehensive investigation of the development of ODR for business to consumer disputes within the EU. This book examines the role of both the European legislator with the Mediation Directive and the English judiciary in encouraging the use of mediation.
Author: Eduardo Baistrocchi Publisher: Cambridge University Press ISBN: 1139916289 Category : Law Languages : en Pages : 975
Book Description
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Author: World Bank Publisher: World Bank Publications ISBN: 1464814414 Category : Business & Economics Languages : en Pages : 241
Book Description
Seventeen in a series of annual reports comparing business regulation in 190 economies, Doing Business 2020 measures aspects of regulation affecting 10 areas of everyday business activity.
Author: Dhruv Sanghavi Publisher: Bloomsbury Publishing ISBN: 9390077745 Category : Business & Economics Languages : en Pages : 232
Book Description
Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom
Author: Jerome Monsenego Publisher: ISBN: 9789144092706 Category : Business & Economics Languages : en Pages : 163
Book Description
Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.
Author: Lisa Bench Nieuwveld Publisher: Kluwer Law International B.V. ISBN: 9041161120 Category : Law Languages : en Pages : 330
Book Description
Since the first edition of this invaluable book in 2012, third-party funding has become more mainstream in international arbitration practice. However, since even the existence of a third-party funding agreement in a dispute is often kept secret, it can be difficult to glean the specifics of successful funding agreements. This welcome book, now updated, expertly reveals the nuances of third-party funding in international arbitration, examines the phenomenon in key jurisdictions, and provides a reliable resource for users and potential users that may wish to tap into and make use of this distinctive funding tool. Focusing on Australia, the United Kingdom, the United States, Germany, the Netherlands, Canada, and South Africa, the authors analyze and assess the legal regime based upon legislation, judicial opinions, ethics opinions, and practitioner anecdotes describing the state of third-party funding in each jurisdiction. In addition to updating summaries of the law of the various jurisdictions, the second edition includes a new chapter addressing third-party funding in investor-state arbitration. Among the issues raised and examined are the following: · payment of adverse costs; · “Before-the-Event” (BTE) and “After-the-Event” (ATE) insurance; · attorney financing: pro bono representation, contingency representation, conditional fee arrangements; · loans; · ethical doctrines affecting the third-party funding industry; · possible future bundling, securitization, and trading of legal claims; · risk that the funder may put its own interests ahead of the client’s interests; and · whether the existence of a funding agreement must or should be disclosed to the decision maker. The second edition also includes discussion of recent institutional developments as they relate to third-party funding, including the work of the ICCA-Queen Mary Task Force on Third-Party Funding and how third-party funding is being incorporated into arbitral rules and investment treaties. Ably providing a thorough understanding of what third-party funding entails and what legal parameters exist, this book will be of compelling interest to parties aiming to take advantage of the high values, speed, reduced evidentiary costs, outcome predictability, industry expertise, and high award enforceability characteristic of the third-party funding arrangements available in international arbitration.
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Author: Christiana HJI Panayi
Author: Eduardo Baistrocchi
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Author: Pablo Cortés
Author: Eduardo Baistrocchi
Author: World Bank
Author: Dhruv Sanghavi
Author: Jerome Monsenego
Author: Lisa Bench Nieuwveld