Italy end inventory 100. Milestone 1 to End. Start to Milestone
|
|
|
- Linda Melton
- 5 years ago
- Views:
Transcription
1 Italy Total MAP Caseload Cases started before 1 January start inventory Cases started Cases closed 217 end inventory Cases started as from 1 January start inventory Cases started Cases closed 217 end inventory 1 Start inventory on Cases started Cases closed End inventory on Cases started as from 1 January 216 Cases started before 1 January 216 Average time needed to close MAP cases (in months) Cases started before 1 January 216 Average time The average time taken to close MAP cases that started before 1 January 216 was computed by applying the following rules: (i) the start date is the date of filing of the MAP request to the Italian competent authority or the date of receipt of the notification letter from the competent authority that received the MAP request from the taxpayer and (ii) the end date is one of the following ones: the date when the taxpayer is informed of the outcome of the MAP process or the date of the closing letter received from the other competent authority or the date of the judgment that resolved the dispute at stake. Cases started as from 1 January 216 Start to End Receipt to Start Start to Milestone 1 Milestone 1 to End Note: the average times to close MAP cases that started as from 1 January 216 were computed according to the MAP statistics reporting framework available at Italy MAP Statistics Page 1/9
2 Overview of MAP partners (only for cases started as from 1 January 216) Note: the MAP cases started before 1 January 216 and closed in 217 are not shown in these graphs Belgium Denmark France Germany Netherlands Spain Sweden Switzerland United Kingdom United States Treaty Partners (de minimis rule applies) Treaty Partners (Others) Cases in 217 start inventory + cases started in 217 Cases closed in Belgium Germany Sweden United Kingdom Treaty Partners (de minimis rule applies) 31 4 Cases in 217 start inventory + cases started in 217 Cases closed in 217 The label "Treaty Partners (de minimis rule applies)" applies to treaty partners with which the number of cases in start inventory plus the number of cases started is at least 5. The relevant MAP statistics are aggregated under this category. The label "Treaty Partners (Others)" applies to treaty partners that are not reporting MAP statistics for the reporting period. The relevant MAP statistics are aggregated under this category. Italy MAP Statistics Page 2/9
3 MAP Outcomes 5% 6% 5% 5% denied MAP access 13% objection is not justified withdrawn by taxpayer unilateral relief granted 16% fully double taxation / fully resolving no including to disagree 5% any other outcome Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving that there is no no including to disagree any other outcome Total (all) Cases started before 1 January Cases started as from 1 January (all) Cases started before 1 January Cases started as from 1 January All cases Italy MAP Statistics Page 3/9
4 Annex A MAP Statistics Reporting for the 217 Reporting Period (1 January 217 to 31 December 217) for Pre-216 Cases Italy number of pre-216 cases closed during the reporting period by outcome: category of cases no. of pre-216 cases in MAP inventory on 1 January 217 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving with partially double taxation / partially resolving with that there is no with no including to disagree any other outcome no. of pre- 216 cases remaining in on MAP inventory on 31 December 217 average time taken (in months) for closing pre- 216 cases during the reporting period Row 1 Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 1 Column 11 Column 12 Column 13 Column 14 Attribution/ Allocation Row 2 Others Row 3 Total (1) The definition of MAP cases is based on the definition contained in the MAP reporting framework arising from the proposals in the Committee on Fiscal Affairs (CFA) 27 report Improving the Resolution of Tax Treaty Disputes. (2) The counting method of MAP cases is based on the counting method contained in the MAP reporting framework arising from the proposals in the Committee on Fiscal Affairs (CFA) 27 report Improving the Resolution of Tax Treaty Disputes. (3) The definitions of Attribution/Allocation MAP Cases and Other MAP Cases are the following: Attribution/Allocation MAP Cases: An attribution/allocation MAP case is a MAP case where the taxpayer s MAP request relates to (i) the attribution of profits to a permanent establishment (see e.g. Article 7 of the OECD Model Tax Convention); or (ii) the determination of profits between associated enterprises (see e.g. Article 9 of the OECD Model Tax Convention), which is also known as a transfer pricing MAP case. Other MAP Cases: Any MAP case that is not an attribution/allocation MAP case. (4) The average time taken reported in Column 14 is based on the method of computing the average cycle time contained in the MAP reporting framework arising from the proposals in the Committee on Fiscal Affairs (CFA) 27 report Improving the Resolution of Tax Treaty Disputes. Italy MAP Statistics Page 4/9
5 MAP Statistics Reporting for the 217 Reporting Period (1 January 217 to 31 December 217) for Post-215 Cases Table 1: Attribution / Allocation MAP Cases number of post-215 cases closed during the reporting period by outcome: Treaty Partner 215 cases in MAP inventory on 1 January cases started during the reporting period denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation eliminated / fully resolving partially double taxation / partially resolving taxation not in with that there is no taxation not in with no including to disagree any other outcome 215 cases remaining in MAP inventory on 31 December 217 Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 1 Column 11 Column 12 Column 13 Column 14 Row 1 Belgium Denmark France Germany Netherlands Spain Sweden Switzerland United Kingdom United States Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Notes According to further information provided by one competent authority, one MAP case has been added in the number of post-215 allocation/attribution cases pending on 1 January 217. Italy MAP Statistics Page 5/9
6 MAP Statistics Reporting for the 217 Reporting Period (1 January 217 to 31 December 217) for Post-215 Cases denied MAP access objection is withdrawn by not justified taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving taxation not in with that there is no with no including to disagree Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 1 Column 11 Column 12 Column 13 Column 14 Row 1 Belgium Germany Sweden United Kingdom Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Treaty Partner 215 cases in MAP inventory on 1 January cases started during the reporting period Table 2: Other MAP Cases number of post-215 cases closed during the reporting period by outcome any other outcome 215 cases remaining in MAP inventory on 31 December 217 Italy MAP Statistics Page 6/9
7 MAP Statistics Reporting for the 217 Reporting Period (1 January 217 to 31 December 217) for Post-215 Cases "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Column 5 Row 1 Belgium Denmark France Germany Netherlands Spain Sweden Switzerland United Kingdom United States Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Treaty Partner Table 1: Attribution / Allocation MAP Cases average time taken (in months) for post-215 cases from: Total Average Time Italy MAP Statistics Page 7/9
8 MAP Statistics Reporting for the 217 Reporting Period (1 January 217 to 31 December 217) for Post-215 Cases "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Column 5 Row 1 Belgium Germany Sweden Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Treaty Partner Table 2: Other MAP Cases average time taken (in months) for post-215 cases from: Total Average Time Italy MAP Statistics Page 8/9
9 MAP Statistics Reporting for the 217 Reporting Period (1 January 217 to 31 December 217) for Post-215 Cases "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Row 1 Total Average Time Table 3: All MAP Cases average time taken (in months) for post-215 cases from: Italy MAP Statistics Page 9/9
Greece. Total MAP Caseload. Average time needed to close MAP cases (in months) n.a. n.a
Greece 35 30 25 Total MAP Caseload Cases started before 1 January 2016 2017 start inventory Cases started Cases closed 2017 end inventory 8 0 2 6 15 0 4 11 20 15 10 5 0 Start inventory on 01.01.2017 Cases
New Zealand. Total MAP Caseload. Average time needed to close MAP cases (in months) n.a. n.a
New Zealand 20 15 Total MAP Caseload Cases started before 1 January 2016 2017 start inventory Cases started Cases closed 2017 end inventory 2 0 2 0 1 0 1 0 10 5 Cases started as from 1 January 2016 2017
Switzerland. Total MAP Caseload. Average time needed to close MAP cases (in months)
Switzerland 4 35 3 25 2 5 5 Start inventory on..27 Total MAP Caseload Cases started Cases closed End inventory on 3.2.27 Cases started before January 26 Cases started as from January 26 27 start inventory
Japan. Total MAP Caseload. Average time needed to close MAP cases (in months)
Japan 140 120 100 Total MAP Caseload Cases started before 1 January 2016 2017 start inventory Cases started Cases closed 2017 end inventory 75 0 20 55 6 0 1 5 80 60 40 20 0 Start inventory on 01.01.2017
Tunisia. Total MAP Caseload. Average time needed to close MAP cases (in months) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.
Tunisia 5 4 Total MAP Caseload Cases started before 1 January 2017 Transfer pricing cases Other cases 2017 start inventory Cases started Cases closed 2017 end inventory 1 0 0 1 3 0 0 3 3 2 1 Cases started
Pakistan. Total MAP Caseload. Average time needed to close MAP cases (in months) n.a. n.a n.a. n.a. n.a. n.a. n.a. n.a.
Pakistan 2 Total MAP Caseload Cases started before 1 January 2016 2017 start inventory Cases started Cases closed 2017 end inventory 0 0 0 0 0 0 0 0 1 Cases started as from 1 January 2016 2017 start inventory
National Tax Agency, Japan
(Mutual Agreement Procedures) Report 214 When international double taxation arises from transfer pricing adjustments or other tax adjustments, the National Tax Agency ( NTA ) enters into Mutual Agreement
Argentina Dispute Resolution Profile. (Last updated: 1 September 2016) General Information
1 Argentina Dispute Resolution Profile (Last updated: 1 September 2016) General Information Argentina s tax treaties are available at: www.afip.gov.ar/institucional/acuerdos.asp MAP request should be made
EU JOINT TRANSFER PRICING FORUM
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Analyses and tax policies Analysis and coordination of tax policies Brussels, 30 May 2005 Taxud/E1/WB DOC: JTPF/019/REV5/2004/EN EU JOINT
OECD releases 2013 Mutual Agreement Procedure statistics
2 December 2014 Global Tax Alert News from Transfer Pricing and Controversy EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
8-Jun-06 Personal Income Top Marginal Tax Rate,
8-Jun-06 Personal Income Top Marginal Tax Rate, 1975-2005 2005 2000 1999 1998 1997 1996 1995 1994 1993 1992 1991 1990 1989 1988 Australia 47% 47% 47% 47% 47% 47% 47% 47% 47% 47% 47% 48% 49% 49% Austria
Georgia Dispute Resolution Profile. (Last updated: 16 December 2016)
1 Georgia Dispute Resolution Profile (Last updated: 16 December 2016) General Information Georgia tax treaties are available at: http://mof.gov.ge/en/4681 MAP request should be made to: Mr. Giorgi Pataridze
MUTUAL AGREEMENT PROCEDURE PROGRAM REPORT
MUTUAL AGREEMENT PROCEDURE PROGRAM REPORT 2016 Competent Authority Services Division International and Large Business Directorate International, Large Business and Investigation Branch Canada Revenue Agency
Chapter 2. Dispute Channels. 1. Overview of common dispute process
Chapter 2 Dispute Channels Suzan Arendsen * This chapter is based on information available up to 1 October 2010. 1. Overview of common dispute process Authorities worldwide increasingly consider transfer
Recommendation of the Council on Tax Avoidance and Evasion
Recommendation of the Council on Tax Avoidance and Evasion OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD Legal Instrument
Switzerland Dispute Resolution Profile. (Last updated: 1 September 2016) General Information
1 Switzerland Dispute Resolution Profile (Last updated: 1 September 2016) General Information Switzerland tax treaties are available at: https://www.admin.ch/opc/fr/classifiedcompilation/0.67.html#0.67
Revenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings
Revenue Arrangements for Implementing EU and OECD Exchange of Information Requirements In Respect of Tax Rulings Page 1 of 21 Table of Contents 1. Introduction...3 2. Overview of Council Directive (EU)
Controversy Trends. EMA Tax Summit. London, September 2016
Controversy Trends EMA Tax Summit London, September 2016 Download the app Open a web browser on your mobile and navigate to http://mobile.globaltaxevent.com Use WiFi for better speed. Select either a native
Switzerland Dispute Resolution Profile. (Last updated: 24 August 2018)
1 Switzerland Dispute Resolution Profile (Last updated: 24 August 2018) General Information Switzerland tax treaties are available at: https://www.admin.ch/opc/fr/classifiedcompilation/0.67.html#0.67 (in
Deadlines to preserve taxpayer rights to request competent authority assistance to relieve double taxation
Arm s Length Standard Global views within reach. Deadlines to preserve taxpayer rights to request competent authority assistance to relieve double taxation Transfer pricing continues to be the top enforcement
EUJOINTTRANSFERPRICINGFORUM PROCEDURAL IMPROVEMENTS TO THE ARBITRATION CONVENTION AND RELATED MUTUALAGREEMENT PROCEDURES
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION TAX POLICY CoordinationofTaxMatters Brussels, 8November2002 C1/WB/LDH DOC:JTPF/007/2002/REV1/EN EUJOINTTRANSFERPRICINGFORUM PROCEDURAL
Egypt Dispute Resolution Profile. (Last updated: 16 October 2018) General Information
1 Egypt Dispute Resolution Profile (Last updated: 16 October 2018) General Information Egypt tax treaties are available at: http://www.incometax.gov.eg/treaties.asp MAP requests should be made to: Ms.
SOME RELEVANT TREATY ISSUES
SOME RELEVANT TREATY ISSUES Rahul Charkha August 29, 2018 CONTENT Sr. No. Topic 1 Glossary 2 Most Favoured Nation Principle 3 Tax Credit 4 Mutual Agreement Procedures 5 Annexure - 1 6 Our Team GLOSSARY
OECD/G20 Base Erosion and Profit Shifting Project. Making Dispute Resolution More Effective MAP Peer Review Report, Spain (Stage 1)
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective MAP Peer Review Report, Spain (Stage 1) Inclusive Framework on BEPS: Action 14 OECD/G20 Base Erosion and Profit
Guidance on Transfer Pricing Documentation and Country-by-Country Reporting
OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting ACTION 13: 2014 Deliverable ANNEX III TO CHAPTER V. A MODEL TEMPLATE FOR THE
TREATY SERIES 2003 Nº 2. Convention on Combating Bribery of Foreign Public Officials in International Business Transactions
TREATY SERIES 2003 Nº 2 Convention on Combating Bribery of Foreign Public Officials in International Business Transactions Done at Paris on 17 December 1997 Signed on behalf of Ireland on 17 December 1997
Making Dispute Resolution More Effective MAP Peer Review Report, Canada (Stage 1)
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective MAP Peer Review Report, Canada (Stage 1) IncluSIve FRAMEwORk on BEPS: ActIOn 14 OECD/G20 Base Erosion and Profit
Paraguay Dispute Resolution Profile. (Last updated: 27 June 2017)
1 Paraguay Dispute Resolution Profile (Last updated: 27 June 2017) General Information Paraguay tax treaties are available at: Under request at the Ministry of Foreign Affairs. MAP request should be made
Guidance on Transfer Pricing Documentation and Country-by-Country Reporting
OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting ACTION 13: 2014 Deliverable ANNEX II TO CHAPTER V. TRANSFER PRICING DOCUMENTATION
Some Basic Facts about Government Expenditures and Taxation in Canada. Econ 525
Some Basic Facts about Government Expenditures and Taxation in Canada Econ 525 Revenues and Expenditures in Canada Since we re studying the role of government in this course it is worth considering some
Third Revised Decision of the Council concerning National Treatment
Third Revised Decision of the Council concerning National Treatment OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD
JOINT STATEMENT. The representatives of the governments of the Member States, meeting within the Council of
JOINT STATEMENT The representatives of the governments of the Member States, meeting within the Council of the EU, and The Swiss Federal Council, Have drawn up the following Joint Statement on company
BEPS Action 14: Making dispute resolution mechanisms more effective
BEPS Action 14: Making dispute resolution mechanisms more effective The Panel Achim Pross, Head, International Cooperation and Tax Administration Division, OECD Doug O Donnell, LB&I Commissioner, IRS Martin
Recommendation of the Council on the Implementation of the Polluter-Pays Principle
Recommendation of the Council on the Implementation of the Polluter-Pays Principle OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces
Statistical annex. Sources and definitions
Statistical annex Sources and definitions Most of the statistics shown in these tables can be found as well in several other (paper or electronic) publications or references, as follows: the annual edition
TAXATION OF TRUSTS IN ISRAEL. An Opportunity For Foreign Residents. Dr. Avi Nov
TAXATION OF TRUSTS IN ISRAEL An Opportunity For Foreign Residents Dr. Avi Nov Short Bio Dr. Avi Nov is an Israeli lawyer who represents taxpayers, individuals and entities. Areas of Practice: Tax Law,
International Tax Europe and Africa October 2017
International Tax Europe and Africa This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa regions between 1 and
International Transfer Pricing Framework
Are you ready for transfer pricing? Seminar on November 28th, 2005 Swissotel, Istanbul International Framework Marc Diepstraten, Partner, PwC Amsterdam, +31 20 568 64 76 PwC Agenda Transfer pricing environment
Double-Taxing Capital Income: How Bad Is the Problem?
November 15, 2006 Double-Taxing Capital Income: How Bad Is the Problem? by Patrick Fleenor Fiscal Fact No. 71 Introduction Double taxation is a common and often misused expression in tax policy discussions.
MULTILATERAL INSTRUMENT
MULTILATERAL INSTRUMENT View from (Dutch) tax practice ACTL seminar / 13 February 2017 Bartjan Zoetmulder / tax partner chair Dutch investment climate team NOB 1 Introduction 2 BEPS implementation phase
APA & MAP COUNTRY GUIDE 2018 UKRAINE. New paths ahead for international tax controversy
APA & MAP COUNTRY GUIDE 2018 UKRAINE New paths ahead for international tax controversy UKRAINE APA PROGRAM KEY FEATURES Competent authority Relevant provisions Types of APAs available Acceptance criteria
OECD releases Switzerland s peer review report on implementation of BEPS Action 14 minimum standards
19 October 2017 Global Tax Alert OECD releases Switzerland s peer review report on implementation of BEPS Action 14 minimum standards EY Global Tax Alert Library Access both online and pdf versions of
APA & MAP COUNTRY GUIDE 2017 MOROCCO
APA & MAP COUNTRY GUIDE 2017 MOROCCO Managing uncertainty in the new tax environment MOROCCO KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance criteria Key
The Socialist Federal Republic of Yugoslavia takes part in some of the work of the OECD (agreement of 28th October 1961).
I 1 Pursuant to article 1 of the Convention signed in Paris on 14th December 1960, and which came into force on 30th September 1961, the Organisation for Economic Co-operation and Development (OECD) shall
What is Transfer Pricing and Why is it Important?
UN-ATAF Workshop on Transfer Pricing Administrative Aspects and Recent Developments Ezulwini, Swaziland 4-8 December 2017 LEARNING OBJECTIVES What is transfer pricing? INTRODUCTION TO TRANSFER PRICING
Global tax audits and disputes: New forces are converging to form second wave
David Swenson, global leader of PwC s tax controversy and dispute resolution network, predicts a second wave of tax audits and disputes is on the horizon around the world. Global tax audits and disputes:
Cboe Europe Index Licence Order Form
1 Please complete all of the applicable fields in this Cboe Europe Index Licence Order Form. You will be notified by Cboe Europe Limited, operating under the trading name Cboe Europe ( Cboe ) once your
IFA MUNICH. Strategic Approaches to Global Transfer Pricing Risk: the use of tax treaties through APA and MAP. 18 January 2018
IFA MUNICH Strategic Approaches to Global Transfer Pricing Risk: the use of tax treaties through APA and MAP 18 January 2018 www.dlapiper.com 86879547 18 January 2018 0 Agenda Current Environment / Current
International Tax Conference
International Tax Conference Hong Kong s Experience with its International Tax Treaty Network Richard Wong Commissioner of Inland Revenue 19 June 2014 1 Introduction Purpose of signing a tax treaty Fairness
OECD Recommendation on Consumer Dispute Resolution and Redress
OECD Recommendation on Consumer Dispute Resolution and Redress ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT The OECD is a unique forum where the governments of 30 democracies work together to
The Government of the Kingdom of the Netherlands. And. The Government of the Isle of Man
Agreement between the Kingdom of the Netherlands and the Isle of Man on the access to mutual agreements procedures in connection with the adjustment of profits of associated enterprises and the application
FCCC/SBI/2010/10/Add.1
United Nations Framework Convention on Climate Change Distr.: General 25 August 2010 Original: English Subsidiary Body for Implementation Contents Report of the Subsidiary Body for Implementation on its
Definition of international double taxation
Definition of international double taxation Juridical double taxation: imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical
Basic information. Tax-to-GDP ratio Date: 29 November 2010
Federal Department of Finance FDF Federal Finance Administration FFA Basic information Date: 29 November 2010 Tax-to-GDP ratio 2010 The tax-to-gdp ratio is the sum of all taxes and public levies in relation
Statistics on APAs in the EU at the End of 2014
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTO UNION Direct taxation, Tax Coordination, Economic Analysis and Evaluation Direct Tax Policy and Cooperation Brussels, October 2015 Taxud/D2 DOC:
OECD releases Italy peer review report on implementation of Action 14 Minimum Standards
22 December 2017 Global Tax Alert OECD releases Italy peer review report on implementation of Action 14 Minimum Standards EY Global Tax Alert Library Access both online and pdf versions of all EY Global
LIST OF ABBREVIATIONS...III LIST OF LEGAL REFERENCES... IV PART I. IMPLEMENTATION OF THE DIRECTIVE... V 1. INTRODUCTION... V
UNITED KINGDOM 535 Page ii OUTLINE LIST OF ABBREVIATIONS...III LIST OF LEGAL REFERENCES... IV PART I. IMPLEMENTATION OF THE DIRECTIVE... V 1. INTRODUCTION... V 1.1. GENERAL INFORMATION ON THE IMPLEMENTATION
New US income tax treaty and protocol with Italy enters into force
22 December 2009 International Tax Alert News and views from Foreign Tax Desks New US income tax treaty and protocol with Italy enters into force Executive summary On 16 December 2009, the United States
Transfer Pricing - Japan
Transfer Pricing - Japan 1. History (1) TP provision for international transactions enacted as Article 66-5 (now Article 66-4) of the Special Taxation Measures Law ( STML ) in 1986 (2) APA created by a
Key Issues in the Design of Capital Gains Tax Regimes: Taxing Non- Residents. 18 July 2014
Key Issues in the Design of Capital Gains Tax Regimes: Taxing Non- Residents 18 July 2014 How do we tax non-residents on capital income? Domestic design issues Tax treaty issues Interrelationship between
APA & MAP COUNTRY GUIDE 2017 CROATIA
APA & MAP COUNTRY GUIDE 2017 CROATIA Managing uncertainty in the new tax environment CROATIA KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance criteria Key
The Independent State of Papua New Guinea Dispute Resolution Profile. (Last updated: )
1 The Independent State of Papua New Guinea Dispute Resolution Profile (Last updated: 16.10.2017) General Information Papua New Guinea tax treaties are available: On request by emailing irclegal@irc.gov.pg.
Statistics on APAs in the EU at the End of 2015
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTO UNION Direct taxation, Tax Coordination, Economic Analysis and Evaluation Direct Tax Policy and Cooperation Brussels, October 2016 Taxud/D2 DOC:
ATAS. 4 and 5 September Anti-Avoidance Rules: Judiciary. Wim Wijnen. Your Portal to Cross-Border Tax Expertise
ATAS 4 and 5 September 2012 Anti-Avoidance Rules: Judiciary Wim Wijnen Counsel to the Academic Chair, IBFD Professor of International Tax Law, LUISS, Rome Judge Court of Appeals, s-hertogenbosch, The Netherlands
Thailand Dispute Resolution Profile. (Last updated: 18 September 2017) General Information
Thailand Dispute Resolution Profile (Last updated: 18 September 2017) General Information Thailand s tax treaties are available at: http://www.rd.go.th/publish/766.0.html MAP request should be made to:
Cash Flow and Working Capital Management
Introduction to Financial Management in SMEs Financial statements analysis Cash Flow and Working Capital Management Investment Projects Appraisal Financing policies in SMEs Cash Flow and Working Capital
Statistics on APAs in the EU at the End of 2016
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Direct taxation, Tax Coordination, Economic Analysis and Evaluation Direct Tax Policy and Cooperation Brussels, March 2018 Taxud/D2 DOC:
Current TP Litigation Scenario Alternative Resolution Mechanisms MAP & APA August 2010
Current TP Litigation Scenario Alternative Resolution Mechanisms MAP & APA Agenda Increasing focus on Transfer Pricing Current litigation status in India Experiences in TP Litigation Alternatives to Litigation
Table 1: Foreign exchange turnover: Summary of surveys Billions of U.S. dollars. Number of business days
Table 1: Foreign exchange turnover: Summary of surveys Billions of U.S. dollars Total turnover Number of business days Average daily turnover change 1983 103.2 20 5.2 1986 191.2 20 9.6 84.6 1989 299.9
Global Environment Facility
Global Environment Facility LDCF/SCCF Council Meeting November 16, 2007 GEF/LDCF.SCCF.3/Inf.2 November 9, 2007 STATUS REPORT ON THE CLIMATE CHANGE FUNDS AS OF SEPTEMBER 30, 2007 (Prepared by the Trustee)
Double Taxation Cases Outside the Transfer Pricing Area
Double Taxation Cases Outside the Transfer Pricing Area December 0 BUSINESSEUROPE a.i.s.b.l AVENUE DE CORTENBERGH 68 BE 000 BRUSSELS BELGIUM TEL + (0) 7 65 FAX + (0) 4 45 E-MAIL MAIN@BUSINESSEUROPE.EU
Bulgaria Dispute Resolution Profile. (Last updated: 16 December 2016)
1 Bulgaria Dispute Resolution Profile (Last updated: 16 December 2016) General Information Bulgaria tax treaties are available at: http://nra.bg/page?id=427 (Bulgarian) http://www.nap.bg/en/page?id=530
Declaration on Environmental Policy
Declaration on Environmental Policy OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD. It reproduces an OECD Legal Instrument and may contain
APA & MAP COUNTRY GUIDE 2017 UNITED STATES
APA & MAP COUNTRY GUIDE 2017 UNITED STATES Managing uncertainty in the new tax environment UNITED STATES KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance
www.bakertillyinternational.com Arm's Length Principle Transfer Pricing Methods From January 1997, as part of the tax reform, new transfer pricing rules based on the arm's length principle have been applicable,
ADVANCE PRICING ARRANGEMENT PROGRAM REPORT
ADVANCE PRICING ARRANGEMENT PROGRAM REPORT 2017 Competent Authority Services Division International and Large Business Directorate International, Large Business and Investigation Branch Canada Revenue
PUBLIC CONSULTATION PAPER. Double Tax Conventions and the Internal Market: factual examples of double taxation cases
PUBLIC CONSULTATION PAPER Double Tax Conventions and the Internal Market: factual examples of double taxation cases Identification of the stakeholder for individual taxpayers Name: CCPR (See also privacy
Learning Goal. To develop an understanding of the Millennium Development Goal targets
Learning Goal To develop an understanding of the Millennium Development Goal targets APK - Activity If you were to set up goals for the world to improve conditions for the world s people, what goals would
COMMISSION OF THE EUROPEAN COMMUNITIES COMMISSION STAFF WORKING DOCUMENT. Annex to the
COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 19122006 SEC(2006) 1690 COMMISSION STAFF WORKING DOCUMENT Annex to the COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE
The Global Tax Reset 2017 Audit Committee Symposium
The Global Tax Reset Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 1 The Global Tax Reset General context Multinational companies
APA & MAP COUNTRY GUIDE 2017 DENMARK
APA & MAP COUNTRY GUIDE 2017 DENMARK Managing uncertainty in the new tax environment DENMARK KEY FEATURES Competent authority Danish Tax Office ( SKAT ) APA provisions/ guidance Types of APAs available
Maldives Dispute Resolution Profile. (Last updated: 29 November 2018) General Information
1 Maldives Dispute Resolution Profile (Last updated: 29 November 2018) General Information Maldives tax treaties are available at: https://www.mira.gov.mv/tax_treaties.aspx MAP requests should be made
Thailand Dispute Resolution Profile. (Last updated: 12 June 2018) General Information
1 Thailand Dispute Resolution Profile (Last updated: 12 June 2018) General Information Thailand tax treaties are available at: http://www.rd.go.th/publish/766.0.html MAP requests should be made to: Mr.
Recommendation of the Council concerning Consumer Protection in the Field of Consumer Credit
Recommendation of the Council concerning Consumer Protection in the Field of Consumer Credit OECD Legal Instruments This document is published under the responsibility of the Secretary-General of the OECD.
European Investment Fund Venture Capital Portfolio. Performance EIF own resources Vintage and Team Location As at 30/06/17
European Investment Fund Venture Capital Portfolio Performance EIF own resources Vintage and Team Location As at 30/06/17 Context All data provided comprise the performance of investments made using EIF
LIST OF ABBREVIATIONS... IV LIST OF LEGAL REFERENCES... V PART I. IMPLEMENTATION OF THE DIRECTIVE... VI 1. INTRODUCTION... VI
ESTONIA 173 Page ii OUTLINE LIST OF ABBREVIATIONS... IV LIST OF LEGAL REFERENCES... V PART I. IMPLEMENTATION OF THE DIRECTIVE... VI 1. INTRODUCTION... VI 1.1. GENERAL INFORMATION ON THE IMPLEMENTATION
BETTER POLICIES FOR A SUCCESSFUL TRANSITION TO A LOW-CARBON ECONOMY
BETTER POLICIES FOR A SUCCESSFUL TRANSITION TO A LOW-CARBON ECONOMY Rintaro Tamaki Deputy Secretary-General, OECD International Forum for Sustainable Asia and the Pacific (ISAP)1 Yokohama, July 1 Four
Costs related to Equity Trading
Costs related to Equity Trading 1. Overview of costs When you buy or sell shares you pay a fee to DNB. The fee is a transaction cost paid when the trade is settled. 1.1 Brokerage fee for Norwegian Shares
THIRD MEETING OF THE OECD FORUM ON TAX ADMINISTRATION
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT THIRD MEETING OF THE OECD FORUM ON TAX ADMINISTRATION 14-15 September 2006 Final Seoul Declaration CENTRE FOR TAX POLICY AND ADMINISTRATION 1 Sharing
STATISTICS. Taxing Wages DIS P O NIB LE E N SPECIAL FEATURE: PART-TIME WORK AND TAXING WAGES
AVAILABLE ON LINE DIS P O NIB LE LIG NE www.sourceoecd.org E N STATISTICS Taxing Wages «SPECIAL FEATURE: PART-TIME WORK AND TAXING WAGES 2004-2005 2005 Taxing Wages SPECIAL FEATURE: PART-TIME WORK AND
Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting 22 December 2017 Chartered Accountants Australia and New Zealand Level 1, Carlaw Park, 12-16
Allocation of income post-beps
Allocation of income post-beps EMA Tax Summit London, September 2016 Download the app Open a web browser on your mobile and navigate to http://mobile.globaltaxevent.com Use WiFi for better speed. Select
SUMMARY REPORT OF THE RESPONSES RECEIVED
SUMMARY REPORT OF THE RESPONSES RECEIVED COMMISSION'S CONSULTATION ON DOUBLE TAXATION CONVENTIONS AND THE INTERNAL MARKET: FACTUAL EXAMPLES OF DOUBLE TAXATION CASES DIRECTORATE-GENERAL FOR TAXATION AND
Corrigendum. OECD Pensions Outlook 2012 DOI: ISBN (print) ISBN (PDF) OECD 2012
OECD Pensions Outlook 2012 DOI: http://dx.doi.org/9789264169401-en ISBN 978-92-64-16939-5 (print) ISBN 978-92-64-16940-1 (PDF) OECD 2012 Corrigendum Page 21: Figure 1.1. Average annual real net investment
European Advertising Business Climate Index Q4 2016/Q #AdIndex2017
European Advertising Business Climate Index Q4 216/Q1 217 ABOUT Quarterly survey of European advertising and market research companies Provides information about: managers assessment of their business
The exchange of international tax information: The Panama Case.
The exchange of international tax information: The Panama Case. 1.The exchange of tax information at an international level: General issues Limitations in Tax Management in the operation for the exchange
ST/SG/AC.8/2001/CRP.15
ST/SG/AC.8/2001/CRP.15 29 August 2001 English Ad Hoc Group of Experts on International Cooperation in Tax Matters Tenth meeting Geneva, 10-14 September 2001 Arbitration in International Tax Matters * *
Slovenia Dispute Resolution Profile. (Last updated: 01 May 2018) General Information
1 Slovenia Dispute Resolution Profile (Last updated: 01 May 2018) General Information Slovenia tax treaties are available at: The list of tax treaties, including the number of relevant Official Gazette
TAX STRUCTURING WITH BILATERAL INVESTMENT TREATIES KIEV ARBITRATION DAYS: THINK BIG CONFERENCE KIEV, UKRAINE NOVEMBER 15, 2013
Richard L. Winston, Esq. Partner (Miami Office) TAX STRUCTURING WITH BILATERAL INVESTMENT TREATIES KIEV ARBITRATION DAYS: THINK BIG CONFERENCE KIEV, UKRAINE NOVEMBER 15, 2013 Copyright 2013 by K&L Gates
CFA Institute Member Poll: Euro zone Stability Bonds
CFA Institute Member Poll: Euro zone Stability Bonds I. About the Survey... 2 a. Background... 2 b. Purpose and Methodology... 2 II. Full Results... 2 Q1: Requirement of common issuance of sovereign bonds...