The Resource Corresponding adjustment and its interaction with the mutual agreement procedure under article 25 of the OECD Model

Corresponding adjustment and its interaction with the mutual agreement procedure under article 25 of the OECD Model

Label
Corresponding adjustment and its interaction with the mutual agreement procedure under article 25 of the OECD Model
Title
Corresponding adjustment and its interaction with the mutual agreement procedure under article 25 of the OECD Model
Creator
Subject
Language
  • eng
  • eng
Summary
Primary transfer pricing adjustments under article 9(1) of the OECD Model in the case of associated enterprises trigger economic double taxation as the same income has already been subject to taxation in the hands of the associated enterprises in other contracting states. The author examines the existing relief mechanism of economic double taxation under article 9(2) of the OECD Model and its interaction with article 25 thereof to find out its effectiveness and suggests possible measures to remedy the shortcomings
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 26 (2019), no. 1 ; p. 12-21
http://library.link/vocab/creatorName
Das, P
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD Model
  • transfer pricing
  • corresponding adjustment
  • MAP
  • double taxation relief
  • tax treaty
  • international tax planning
Label
Corresponding adjustment and its interaction with the mutual agreement procedure under article 25 of the OECD Model
Instantiates
Publication
Note
20190312
Other control number
itpj_2019_01_int_4.html
Label
Corresponding adjustment and its interaction with the mutual agreement procedure under article 25 of the OECD Model
Publication
Note
20190312
Other control number
itpj_2019_01_int_4.html

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