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Mandatory Arbitration Procedures: A New Tack for Resolving Double Taxation Disputes between Competent Authorities
Global Business Information Strategies, Inc. , Oct 2008, Pages: 11
Current mutual agreement procedures leave taxpayers vulnerable to double taxation when tax authorities from different countries disagree about the arm’s length value of a transaction. Under current procedures, the taxpayer has no guarantee that differences of tax treatment resulting in double taxation will be resolved between the tax authorities in a timely manner and even when a decision is reached that relieves the taxpayer of the burden of paying taxes twice on the same income, there is no relief from accrued interest penalties available.
Recent income tax agreements, including the Proposed U.S.-Belgium Convention, which is currently being considered for ratification, would offer additional protections to taxpayers, including a definite timeline for the resolution of these disputes, but further improvements are needed if problems such as accrued interest penalties and the possibility of failure by both competent authorities in a dispute to file proposed resolutions are to be addressed. By Michael Plodek, Lockheed Martin.
*Please note that this article is too short to contain a table of contents*
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