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Is the interaction between chapter X of the OECD Transfer Pricing Guidelines and the EU Directive on Tax Dispute Resolution Mechanisms an effective one? electrónico Hans van den Hurk

By: Hurk, Hans van den.
Material type: ArticleArticleSubject(s): PRECIOS DE TRANSFERENCIA | RESOLUCIONES EXTRAJUDICIALES DE CONFLICTOS | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO | GUIAS | DERECHO COMUNITARIO EUROPEO | UNION EUROPEA | DERECHO COMPARADO In: International Transfer Pricing Journal v. 29, n. 1, 2022, p. 35-44 Summary: International tax law has been developing rapidly for years. In this article, the author tests the consequences of the new chapter X of the OECD Transfer Pricing Guidelines against the EU Arbitration Directive and the Dutch Tax Arbitration Act. He concludes that, because the Directive does not cover differences in qualification, various situations will fall between two stools.
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Resumen.

International tax law has been developing rapidly for years. In this article, the author tests the consequences of the new chapter X of the OECD Transfer Pricing Guidelines against the EU Arbitration Directive and the Dutch Tax Arbitration Act. He concludes that, because the Directive does not cover differences in qualification, various situations will fall between two stools.

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