Solving double taxation outside the realm of a mutual agreement procedure Eric Vroemen
By: Vroemen, Eric
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Material type: 
ArticlePublisher: 2019Subject(s): PRECIOS DE TRANSFERENCIA | DOBLE IMPOSICION | CONVENIO MULTILATERAL
In:
International Transfer Pricing Journal v. 26, n. 2, March / April 2019, p. 114-117Summary: As transfer pricing adjustments are expected to increase, so will be mutual agreement procedure requests in order to remedy the resulting double taxation. To forego the downsides of this procedure, this article suggests that a MAP should be preceded by an attempt to obtain an unilateral corresponding adjustment. In the Netherlands, such an instrument is available and is called a pre-emptive MAP request.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2019/2-6 (Browse shelf) | Available | ITPJ/2019/2-6 |
Disponible únicamente en formato electrónico en la Biblioteca del IEF.
Resumen.
As transfer pricing adjustments are expected to increase, so will be mutual agreement procedure requests in order to remedy the resulting double taxation. To forego the downsides of this procedure, this article suggests that a MAP should be preceded by an attempt to obtain an unilateral corresponding adjustment. In the Netherlands, such an instrument is available and is called a pre-emptive MAP request.
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