International Tax

Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (H-K) (Portfolio 6890)

  • Bloomberg Tax Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (H–K), No. 6890, discusses the competent authority functions and procedures of India, Ireland, Italy, and Korea.

Description

Tax Management Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (H–K), No. 6890, discusses the competent authority functions and procedures of India, Ireland, Italy, and Korea. 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 Gandhi, et al., 6890 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (H–K).

Table of Contents

75:I. Introduction
75:II. The Competent Authority of India
75:III. The Mutual Agreement Procedure for Taxpayer Cases
75:IV. Advance Pricing Agreements
75:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
75:VI. Exchange of Information
75:VII. Assistance in Tax Collection
80:I. Introduction
80:II. The Irish Competent Authority
80:III. The Mutual Agreement Procedure for Taxpayer Cases
80:IV. Advance Pricing Agreements
80:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
80:VI. Exchange of Information
80:VII. Assistance in Tax Collection
85:I. Introduction
85:II. Italian Competent Authority
85:III. Mutual Agreement Procedure in Taxpayer Cases
85:IV. Advance Pricing Agreements
85:V. Exchange of Information
85:VI. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
85:VII. Assistance in Tax Collection
95:I. Introduction
95:II. The Competent Authority of Korea
95:III. The Mutual Agreement Procedure for Taxpayer Cases (MAP)
95:IV. Advance Pricing Agreements
95:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
95:VI. Exchange of Information
95:VII. Assistance in Tax Collection

Samir Gandhi
Partner
Deloitte India
Rakesh_Alshi
Rakesh Alshi
Partner
Deloitte Haskins & Sells, Chartered
Kavita_Sethia_Gambhir
Kavita Sethia Gambhir
Senior Manager
Deloitte Haskins & Sells LLP
phelan-martin-2015
Martin Phelan
Partner
William Fry Tax Advisors
Aldo Castoldi
Aldo Castoldi
Tax Partner
Studio Tributario e Societario, Del
kim_tae_hyung_2015
Taehyung Kim
Attorney
DELOITTE ANJIN LLC
Yong Chan Lee
Yong Chan Lee
Partner
Deloitte Anjin LLC
Jae Seong (Jason) Yun
Jae Seong (Jason) Yun
Director
Ernst & Young
Sumin Kim
Deloitte Anjin LLC
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