The Resource Treaties and transfer pricing penalties

Treaties and transfer pricing penalties

Label
Treaties and transfer pricing penalties
Title
Treaties and transfer pricing penalties
Creator
Subject
Language
eng
Summary
The authors try to answer the question why penalties are never discussed in competent authority negotiations. They believe countries worldwide should adopt a policy of negotiating transfer pricing penalties in mutual agreement procedures (MAP) cases whenever the taxpayer has made a serious effort to meet documentation requirements. The article considers treaty provisions, US transfer pricing penalties and treaty partners' transfer pricing penalties, MAP for transfer pricing penalties, and the impact on self-initiated adjustments
Citation source
In: Tax notes international. - Falls Church. - Vol. 67 (2012),
http://library.link/vocab/creatorName
  • Chamberlain, D.G
  • Foley, S.F
  • Krider, W
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • transfer pricing
  • penalties
  • tax treaty
  • MAP
  • transfer pricing adjustment
Label
Treaties and transfer pricing penalties
Instantiates
Publication
Label
Treaties and transfer pricing penalties
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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