It is in the interest of most states to eliminate double taxation (i.e. the payment of the same tax in two jurisdictions) of transnational commercial enterprises. Because such disputes involve, on the one hand, the state imposition of taxes, a right universally asserted by all states, and private entities on the other, taxation disputes between such parties are not, on their face, easily susceptible to arbitration. This article analyzes two dispute settlement procedures-the OECD First Model Tax Convention and a similar EU Convention-with the exclusive focus on disputes relating to the imposition of double taxation. It will look at the ways in which state roles may vary under these procedures from assisting in the negotiation process to taki...
In bilateral tax treaties each self-interested state confers benefits to another State because it ex...
Undertaking economic activity by natural and legal persons on territories of foreign countries brin...
This Briefing summarises ICTD Working Paper 55, which examines the Mutual Agreement Procedure (MAP) ...
It is in the interest of most states to eliminate double taxation (i.e. the payment of the same...
In this article the author advocates compulsory arbitration as a subsidiary mechanism to guarantee t...
For several years Article 25 of the Model Tax Convention of the Organisation for Economic Co-operati...
This paper explores the addition of arbitration into the Mutual Agreement Procedure of the OECD’s Mo...
Introductory remarks on the arbitration method in international tax matters; The evolution of inter...
Il lavoro di ricerca è diretto ad individuare il ruolo dell'istituto arbitrale nell’àmbito degli str...
Avec l’accroissement des échanges transfrontaliers entre entreprises associées et des moyens de cont...
Arbitration, even if it seems simply providing for the possibility of arbitration, is increasingly a...
One of the goals of bilateral tax conventions is mitigating instances of double taxation for each st...
Over the past years, "arbitration" as a means of settling international disputes has gained populari...
Improving the resolution of international tax disputes has witnessed recent developments. The Organi...
O presente estudo trata do procedimento amigável e da arbitragem como métodos de solução de contrové...
In bilateral tax treaties each self-interested state confers benefits to another State because it ex...
Undertaking economic activity by natural and legal persons on territories of foreign countries brin...
This Briefing summarises ICTD Working Paper 55, which examines the Mutual Agreement Procedure (MAP) ...
It is in the interest of most states to eliminate double taxation (i.e. the payment of the same...
In this article the author advocates compulsory arbitration as a subsidiary mechanism to guarantee t...
For several years Article 25 of the Model Tax Convention of the Organisation for Economic Co-operati...
This paper explores the addition of arbitration into the Mutual Agreement Procedure of the OECD’s Mo...
Introductory remarks on the arbitration method in international tax matters; The evolution of inter...
Il lavoro di ricerca è diretto ad individuare il ruolo dell'istituto arbitrale nell’àmbito degli str...
Avec l’accroissement des échanges transfrontaliers entre entreprises associées et des moyens de cont...
Arbitration, even if it seems simply providing for the possibility of arbitration, is increasingly a...
One of the goals of bilateral tax conventions is mitigating instances of double taxation for each st...
Over the past years, "arbitration" as a means of settling international disputes has gained populari...
Improving the resolution of international tax disputes has witnessed recent developments. The Organi...
O presente estudo trata do procedimento amigável e da arbitragem como métodos de solução de contrové...
In bilateral tax treaties each self-interested state confers benefits to another State because it ex...
Undertaking economic activity by natural and legal persons on territories of foreign countries brin...
This Briefing summarises ICTD Working Paper 55, which examines the Mutual Agreement Procedure (MAP) ...