International Tax

Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (A-C) (Portfolio 6885)

  • This Portfolio discusses the competent authority functions and procedures of Australia, Austria, Belgium, Canada, Chile, and China.

Description

This Bloomberg Tax Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (A–C), No. 6885, discusses the competent authority functions and procedures of Australia, Austria, Belgium, Canada, Chile, and China. Each chapter initially focuses on the mutual agreement procedure that is available to taxpayers subject to double taxation, and in that connection discusses such topics as the basic procedure for requesting competent authority relief, statute of limitations issues, the role of Appeals (if any), the small case procedure (if any), interest on deficiencies and refunds, and the possibility of arbitration. If a country also has procedures for Advance Pricing Agreements, those are also considered.

Each chapter then discusses the procedures relating to consultation between competent authorities regarding the interpretation or application of an income tax treaty, exchange of information, and assistance in collection. With respect to exchange of information, each chapter also considers procedures under any tax information exchange agreements to which the country is a party.

For competent authority functions and procedures of the United States, see 940 T.M., U.S. Income Tax Treaties — U.S. Competent Authority Functions and Procedures.

This Portfolio may be cited as Lewis, et al., 6885 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (A–C).

Table of Contents

10:I. Introduction
10:II. Australian Competent Authority
10:III. Mutual Agreement Procedure in Taxpayer Cases
10:IV. Advance Pricing Arrangements
10:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
10:VI. Exchange of Information
15:I. Introduction
15:II. The Competent Authority of Austria
15:III. The Mutual Agreement Procedure for Taxpayer Cases
15:IV. Advance Pricing Agreements
15:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
15:VI. Exchange of Information
15:VII. Assistance in Tax Collection
20:I. Introduction
20:II. The Belgian Competent Authority
20:III. The Mutual Agreement Procedure
20:IV. Advance Pricing Agreements
20:V. Consultations Between Competent Authorities Regarding Treaty Interpretation or Application
20:VI. Exchange of Information and Administrative Assistance
20:VII. Assistance in Collection
30:I. Introduction
30:II. Mutual Agreement Procedure
30:III. Advance Pricing Arrangements
30:IV. Consultation Between Competent Authorities on Treaty Matters
30:V. Competent Authority and Limitation on Benefits
30:VI. Exchange of Information
30:VII. Assistance in Tax Collection
35:I. Introduction
35:II. Mutual Agreement Procedure in Chile’s Income Tax Treaties
35:III. Exchange of Information
35:IV. New Transfer Pricing Rules Introduced by the Tax Reform
40:I. Introduction
40:II. The Competent Authority of China
40:III. The Mutual Agreement Procedure for Taxpayer Cases
40:IV. Advance Pricing Arrangements
40:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
40:VI. Exchange of Information
40:VII. Assistance in Tax Collection

Dave Lewis
Dave Lewis
Deloitte Touche Tohmatsu
Niklas_Schmidt
Niklas Schmidt
Partner
Wolf Theiss
Eva-Stadler
Eva Stadler
Senior Associate
Wolf Theiss Rechtsanwälte Gmbh & Co
Patrick_cauwenbergh
Patrick Cauwenbergh
Partner, Corporate International Tax
Deloitte Belastingconsulenten
gaublomme-ann-2015
Ann Gaublomme
Director Transfer Pricing
Deloitte Belgium
vanmechelen_wouter_2015
Wouter Vanmechelen
Avnet
chong-henry-2015
Henry Chong
Income Tax Rulings Directorate - Reorganizations Division
Canada Revenue Agency
carey-jaime-2015
Jaime Carey
Managing Partner
Carey Y Cía Ltda.
pfeffer-daniela-2015
Daniela Pfeffer
Associate
Carey Y Cía Ltda.
cheung_patrick_2015
Patrick Cheung
Partner
Deloitte Touche Tohmatsu
tien-jessica-2015
Jessica Tien
Principal Economist
lai-becky-2015
Becky Lai
Senior Advisor, International Tax & Tax Policy Services
Ernst & Young Tax Services Limited