International Tax

Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (D-G) (Portfolio 6887)

  • This Portfolio discusses the competent authority functions and procedures of Denmark, France, and Germany.

Description

The Bloomberg Tax Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (D–G), No. 6887, discusses the competent authority functions and procedures of Denmark, France, and Germany. 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 Wittendorff, Monsellato, Lesprit, Golz, Nientimp, and Roeder, 6887 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (D–G).

Table of Contents

45:I. Introduction
45:II. Competent Authority
45:IV. Arbitration
45:V. Advance Pricing Agreements
45:VI. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
45:VII. Exchange of Information
45:VIII. Assistance in Tax Collection
50:I. Introduction
50:II. The Competent Authority of France
50:III. The Mutual Agreement Procedure for Taxpayer Cases
50:IV. Advance Pricing Agreements
50:V. Exchange of Information
50:VI. Assistance in Tax Collection
55:I. Introduction
55:II. The German Competent Authority
55:III. The MAP for Taxpayer Cases and Arbitration Procedures
55:IV. Advance Pricing Agreements
55:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application Introductory Material
55:VI. Exchange of Information
55:VII. Assistance in Tax Collection

Jens-Wittendorff
Jens Wittendorff
International Tax Partners
Ernst & Young LLP
monsellato-gianmarco-2015
Gianmarco Monsellato
Managing Partner / Ceo
Taj Société D'Avocats
Eric-Lesprit-1-
Eric Lesprit
Partner
Taj
Silke_Golz
Silke Golz
Senior Manager, Transfer Pricing
PricewaterhouseCoopers LLP
Alex-Nientimp
Axel Nientimp
Partner, Tax, Global Transfer Pricing Services
KPMG
Achim Roeder
Partner
KPMG AG Wirtschaftsprüfungsgesellsc
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