Items
Details
Table of Contents
Cover
Title
Copyright
Preface
Introduction
1. Background and reason of the research
1.1. Growing number of cross-border tax disputes
1.2. Flexible multi-tier solutions for international tax disputes
1.3. Mediation in international tax disputes
2. Purpose and scope of the research
3. Methodology, approach and the research partners
Appendix 1: Research Blocks
Stage 0-2 (excluding mediation): Prevention and facilitation of the settlement of tax disputes
Stage 2: Mediation
Stage 3
Part I: Prevention of Tax Disputes and Facilitation of Their Settlement in Domestic and Cross-Border Situations
Chapter 1: Flexible Multi-Tier Dispute Resolution: The Croatian Experience
1.1. Introduction
1.2. Prevention of international tax disputes
1.2.1. Domestic: Between taxpayers and tax authorities
1.2.2. International: Between disputing states
1.3. Partners are capable of dealing with international tax disputes
1.3.1. Domestic: Between taxpayers and tax authorities
1.3.1.1. General framework
1.3.1.2. Mechanisms to guarantee the correct interpretation of tax legislation
1.3.1.2.1. Rulings
1.3.1.2.2. APAs (advance pricing agreements)
1.3.1.2.3. Final interview
1.3.1.2.4. Tax settlement
1.3.2. International: Between states
1.4. Concluding remarks
Chapter 2: Flexible Multi-Tier Dispute Resolution: The German Experience
2.1. Introduction
2.2. Unilateral procedures dealing with international tax disputes between taxpayers and tax authorities within a state
2.2.1. Rulings regarding future transactions
2.2.1.1. Advance rulings
2.2.1.2. Unilateral APA
2.2.1.3. Enhanced relationships
2.2.2. Contracts under public law regarding past transactions
2.3. Bi- or multilateral procedures dealing with international tax disputes between states
2.3.1. Bi- or multilateral APA
2.3.2. Cross-border rulings, cooperation and information exchange
2.4. Summary
The Use of Independent Non-Judicial Bodies in the Settlement of Tax Disputes: Selected National Experiences
Chapter 3: The Use of a Third Person other than a Court in Order to Deal with Tax Disputes: The Greek Experience
3.1. Introduction
3.2. The use of third parties for the resolution of domestic tax disputes between the state and the taxpayer
3.2.1. The Directorate for Dispute Resolution of the Independent Authority for Public Revenue
3.2.2. The Greek Ombudsman
3.3. The use of third parties for the resolution of international tax disputes between states
3.4. Concluding remarks
Chapter 4: The Settlement Commission in the Indian Experience
4.1. Background
4.2. The evolution of the essential legal provisions in brief
4.3. Procedure to be followed upon receipt of application for settlement
Title
Copyright
Preface
Introduction
1. Background and reason of the research
1.1. Growing number of cross-border tax disputes
1.2. Flexible multi-tier solutions for international tax disputes
1.3. Mediation in international tax disputes
2. Purpose and scope of the research
3. Methodology, approach and the research partners
Appendix 1: Research Blocks
Stage 0-2 (excluding mediation): Prevention and facilitation of the settlement of tax disputes
Stage 2: Mediation
Stage 3
Part I: Prevention of Tax Disputes and Facilitation of Their Settlement in Domestic and Cross-Border Situations
Chapter 1: Flexible Multi-Tier Dispute Resolution: The Croatian Experience
1.1. Introduction
1.2. Prevention of international tax disputes
1.2.1. Domestic: Between taxpayers and tax authorities
1.2.2. International: Between disputing states
1.3. Partners are capable of dealing with international tax disputes
1.3.1. Domestic: Between taxpayers and tax authorities
1.3.1.1. General framework
1.3.1.2. Mechanisms to guarantee the correct interpretation of tax legislation
1.3.1.2.1. Rulings
1.3.1.2.2. APAs (advance pricing agreements)
1.3.1.2.3. Final interview
1.3.1.2.4. Tax settlement
1.3.2. International: Between states
1.4. Concluding remarks
Chapter 2: Flexible Multi-Tier Dispute Resolution: The German Experience
2.1. Introduction
2.2. Unilateral procedures dealing with international tax disputes between taxpayers and tax authorities within a state
2.2.1. Rulings regarding future transactions
2.2.1.1. Advance rulings
2.2.1.2. Unilateral APA
2.2.1.3. Enhanced relationships
2.2.2. Contracts under public law regarding past transactions
2.3. Bi- or multilateral procedures dealing with international tax disputes between states
2.3.1. Bi- or multilateral APA
2.3.2. Cross-border rulings, cooperation and information exchange
2.4. Summary
The Use of Independent Non-Judicial Bodies in the Settlement of Tax Disputes: Selected National Experiences
Chapter 3: The Use of a Third Person other than a Court in Order to Deal with Tax Disputes: The Greek Experience
3.1. Introduction
3.2. The use of third parties for the resolution of domestic tax disputes between the state and the taxpayer
3.2.1. The Directorate for Dispute Resolution of the Independent Authority for Public Revenue
3.2.2. The Greek Ombudsman
3.3. The use of third parties for the resolution of international tax disputes between states
3.4. Concluding remarks
Chapter 4: The Settlement Commission in the Indian Experience
4.1. Background
4.2. The evolution of the essential legal provisions in brief
4.3. Procedure to be followed upon receipt of application for settlement