Transfer Pricing and Dispute Resolution PDF Download

Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087221002
Category : Dispute resolution (Law).
Languages : en
Pages : 807

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Book Description
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.

Author: Werner Haslehner
Publisher: Edward Elgar Publishing
ISBN: 178990577X
Category : Law
Languages : en
Pages : 364

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Book Description
This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.

Author: Dr. (Adv) Priyanka Shokeen
Publisher: Casa Editorial
ISBN: 8197765898
Category : Business & Economics
Languages : en
Pages : 250

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Book Description
This book on Taxation Dispute Resolution Mechanism with Special Reference to International Trade explores the intricate legal and procedural frameworks governing tax-related conflicts in global commerce. It delves into the What is dispute and how it can effect any economy it also delves into intersection of tax law and international trade, analyzing the mechanisms designed to resolve disputes between multinational corporations and tax authorities. Key areas include bilateral and multilateral treaties, such as the OECD Model Tax Convention, and how they address tax evasion, double taxation, and transfer pricing issues. The book also examines arbitration and mediation as effective tools for resolving such disputes, comparing various countries' approaches and international organizations' roles in shaping dispute resolution frameworks. In the context of globalization, your book highlights the growing complexity of tax-related disagreements, emphasizing the need for streamlined processes to promote trade without compromising tax compliance. The work provides a critical analysis of case law, treaties, and dispute settlement mechanisms to guide practitioners, policymakers, and academics.

Author: Saka Muhammed Olokooba
Publisher: Springer
ISBN: 981132607X
Category : Law
Languages : en
Pages : 200

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Book Description
This book offers a simplified and straightforward introduction to the basics of Nigerian taxation. While discussing various laws, practices and procedures, it also addresses the latest amendments to Nigerian tax laws. The book begins by discussing the central issue of Islamic taxation and its legality under Nigerian law. Divided into four main sections, the book was designed for simplicity, and uses language that is accessible for all tax stakeholders.

Author: Asif H. Qureshi
Publisher: Kluwer Law International B.V.
ISBN: 9041184775
Category : Law
Languages : en
Pages : 912

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Book Description
The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.

Author: Michael L. Moffitt
Publisher: John Wiley & Sons
ISBN: 1118429834
Category : Law
Languages : en
Pages : 580

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Book Description
This volume is an essential, cutting-edge reference for all practitioners, students, and teachers in the field of dispute resolution. Each chapter was written specifically for this collection and has never before been published. The contributors--drawn from a wide range of academic disciplines--contains many of the most prominent names in dispute resolution today, including Frank E. A. Sander, Carrie Menkel-Meadow, Bruce Patton, Lawrence Susskind, Ethan Katsh, Deborah Kolb, and Max Bazerman. The Handbook of Dispute Resolution contains the most current thinking about dispute resolution. It synthesizes more than thirty years of research into cogent, practitioner-focused chapters that assume no previous background in the field. At the same time, the book offers path-breaking research and theory that will interest those who have been immersed in the study or practice of dispute resolution for years. The Handbook also offers insights on how to understand disputants. It explores how personality factors, emotions, concerns about identity, relationship dynamics, and perceptions contribute to the escalation of disputes. The volume also explains some of the lessons available from viewing disputes through the lens of gender and cultural differences.

Author: OECD
Publisher: OECD Publishing
ISBN: 9264424083
Category :
Languages : en
Pages : 355

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Book Description
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.

Author: John Brondolo
Publisher: International Monetary Fund
ISBN: 1475523610
Category : Business & Economics
Languages : en
Pages : 67

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Book Description
Tax administration improvements have contributed significantly to a doubling of China’s tax-to-GDP ratio and the substantial reduction in taxpayers’ compliance costs since the mid-1990s. This paper describes the key features of China’s tax administration and their evolution over the last 20 years. It also identifes emerging challenges to the tax system and areas where further tax administration improvements are needed to sustain tax revenue and reduce taxpayers’ compliance costs in the future.

Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
ISBN: 1108150381
Category : Law
Languages : en
Pages : 2216

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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: Francis Mbago
Publisher: GRIN Verlag
ISBN: 366878812X
Category : Law
Languages : en
Pages : 28

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Book Description
Essay from the year 2018 in the subject Law - Miscellaneous, , course: LLB, language: English, abstract: Tax dispute implies the general conflict or disagreement between tax authority and tax payer arising from the decision of commissioner general. Such disagreement is normally caused by either poor interpretation of statutes or tax avoidance. Tax Payment is a mandatory requirement for every person who has income derived either from employment, business or investment in the year of income as provided under section 4 of Income Tax Act In a general sense, a tax is any contribution imposed by the government upon individuals, for the use and service of the state, whether under the name of toll, tribute, tallage, gabel, impost, duty, or other name. The discussion on Tax Dispute Mechanism is important phenomena following the fact that its implications amounts to costly outcome financially especially to tax payers and the government as well. Such discussion is even more relevant now given the fact that the current government focuses much on tax collection having zero tolerance on non-compliance with tax laws This presents is categorized into six main parts, where part of this of work introduces the concept of tax, its legal justification, legality and the relevancy of taxation. Part two discusses the general context of Tax Dispute Mechanism, legality and fairness principle with regards to the Tax Statutes. Parts three ponders on the procedures on Tax Dispute. Part four details the procedures of institution of appeal to the Board, whereas part five details procedures of institution appeal to the Tribunal and Finally Part Six concludes the work. Tax collection is mandated to TRA and its implementation lies on various tax officers and commissioners. Tax decisions in Tanzania are in the legal capacity of the Commissioner General of TRA. The knowledge of Tax Dispute Settlement is an important phenomenon to both tax authority and tax payers as it fosters efficiency in Tax Administration. With that view these presents intends to discuss tax disputes mechanisms in Tanzania with the precise intent of ushering knowledge of procedures with regards to tax dispute settlement mechanism.