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2021 Guidance on MAPs electrónico Gabriella Erdős

By: Erdös, Gabriella.
Material type: ArticleArticleSubject(s): DOBLE IMPOSICION | CONVENIOS | TRATADOS INTERNACIONALES | PRECIOS DE TRANSFERENCIA | RESOLUCIONES EXTRAJUDICIALES DE CONFLICTOS | HUNGRIA In: International Transfer Pricing Journal v. 29, n. 1, 2022, p. 61-65Summary: The mutual agreement procedure (MAP) is an instrument for the resolution of international tax disputes whenever a person considers that the actions of the tax authorities result in taxation not in accordance with the provisions of a tax treaty or an international agreement. This article analyses Hungary’s recent MAP guidelines regarding double tax treaties, a dispute resolution directive, and arbitration convention-based MAPs, and their application to transfer pricing cases. It also elaborates on the recent structural changes within the competent authorities.
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Resumen.

The mutual agreement procedure (MAP) is an instrument for the resolution of international tax disputes whenever a person considers that the actions of the tax authorities result in taxation not in accordance with the provisions of a tax treaty or an international agreement. This article analyses Hungary’s recent MAP guidelines regarding double tax treaties, a dispute resolution directive, and arbitration convention-based MAPs, and their application to transfer pricing cases. It also elaborates on the recent structural changes within the competent authorities.

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