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Reaching cross-border tax certainty with joint audits Isabella Zimmerl

By: Zimmerl, Isabella.
Material type: ArticleArticleSubject(s): INSPECCION TRIBUTARIA | COLABORACION TRIBUTARIA | COOPERACIÓN ADMINISTRATIVA | ARMONIZACION FISCAL | ACUERDOS PREVIOS SOBRE PRECIOS DE TRANSFERENCIA | UNION EUROPEA In: EC Tax Review v. 31, n. 6, December 2022, p. 300-311Summary: The last few years have seen an increasing cooperation between tax authorities of Member States of the European Union by way of joint audits. This article shows how joint audits can provide an efficient solution to double taxation issues faced by internationally active companies. It centres on ways to amend and effectuate existing procedures of international tax law in light of experiences made with joint audits, focusing in particular on potential ways for more cross-border tax certainty. Furthermore, the article illustrates that an effective und legally certain reduction of international double taxation can best be reached by a stronger cooperation of tax authorities and the taxpayer/s. Finally, the author takes a look at recent developments in the field as well as the potential future of joint audits, emphasizing the need for more legally binding solutions.
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Resumen.

The last few years have seen an increasing cooperation between tax authorities of Member States of the European Union by way of joint audits. This article shows how joint audits can provide an efficient solution to double taxation issues faced by internationally active companies. It centres on ways to amend and effectuate existing procedures of international tax law in light of experiences made with joint audits, focusing in particular on potential ways for more cross-border tax certainty. Furthermore, the article illustrates that an effective und legally certain reduction of international double taxation can best be reached by a stronger cooperation of tax authorities and the taxpayer/s. Finally, the author takes a look at recent developments in the field as well as the potential future of joint audits, emphasizing the need for more legally binding solutions.

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