The Resource Arbitration Convention 90/436/EEC : inapplicability in case of serious penalties

Arbitration Convention 90/436/EEC : inapplicability in case of serious penalties

Label
Arbitration Convention 90/436/EEC : inapplicability in case of serious penalties
Title
Arbitration Convention 90/436/EEC : inapplicability in case of serious penalties
Creator
Subject
Language
eng
Summary
A tool for settling transfer pricing controversies is the EU Arbitration Convention No. 90/436/EEC. If a double taxation in transfer pricing occurs, the enterprise may submit its case to the competent authority of the state in which it resides, regardless of the remedies provided by domestic provisions. Where the claim is legitimate, the competent authority shall initiate a mutual agreement procedure (MAP) with the authority of the other state to settle the controversy. If no agreement is reached within two years, the controversy shall be submitted to an advisory Commission charged with the delivery of an opinion. The competent authority of a state shall not be obliged to initiate a MAP or set up an advisory Commission should the enterprise be liable to serious penalties
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 40 (2012),
http://library.link/vocab/creatorName
Valente, P
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • Arbitration Convention
  • double taxation
  • MAP
  • penalties
Label
Arbitration Convention 90/436/EEC : inapplicability in case of serious penalties
Instantiates
Publication
Label
Arbitration Convention 90/436/EEC : inapplicability in case of serious penalties
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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