International Tax

Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (L-N) (Portfolio 6892)

  • This Portfolio discusses the competent authority functions and procedures of Luxembourg, Mexico, Netherlands, New Zealand, and Norway.

Description

The Bloomberg Tax Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (L–N), No. 6892, discusses the competent authority functions and procedures of Luxembourg, Mexico, Netherlands, New Zealand, and Norway. 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 Tilquin, et al., 6892 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (L–N).

Table of Contents

100:I. Introduction
100:II. Luxembourg Competent Authority
100:III. Mutual Agreement Procedure in Taxpayer Cases
100:IV. Advance Pricing Agreements
100:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
100:VI. Exchange of Information
110:I. Introduction
110:II. The Competent Authority of Mexico
110:III. The Mutual Agreement Procedure for Taxpayer Cases
110:IV. Advance Pricing Agreements
110:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
110:VI. Exchange of Information
110:VII. Assistance in Tax Collection
115:I. Introduction
115:II. The Dutch Competent Authority
115:III. The Mutual Agreement Procedure in Taxpayer Cases
115:IV. Advanced Pricing Agreement
115:V. Exchange of Information
115:VI. International Investor’s Desk
120:I. Introduction
120:II. Competent Authority of New Zealand
120:III. The Mutual Agreement Procedure for Taxpayer Cases
120:IV. The Process
120:V. Advance Pricing Agreements
120:VI. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
120:VII. Exchange of Information
120:VIII. Assistance in Collection
125:I. Introduction
125:II. Competent Authority
125:III. Sources of Law and Rules of Interpretation
125:IV. MAP — Taxpayer Cases — Requirements for Initiating the MAP
125:V. Responsibilities and Powers of Competent Authorities in a MAP
125:VI. The Relationship Between Domestic Remedies and the MAP
125:VII. The Rights of the Taxpayer
125:VIII. Implementation of the Mutual Agreement
125:IX. Advance Pricing Agreements
125:X. Exchange of Information — Model Convention Article 26
125:XI. Tax Information Exchange Agreements (TIEAs)
125:XII. Assistance in Tax Collection
125:XIII. FATCA Intergovernmental Agreement (IGA) Between Norway and the United States

stephan_tilquin
Stephan Tilquin
Director | Cross-Border Tax - International Tax Corporate
Deloitte SA
Dinko Dinev
Dinko Dinev
Director
Deloitte, Luxembourg
Ricardo Gonzalez Orta
Deloitte Mexico
Mauricio Martínez D´Meza Violante
Partner
Deloitte Mexico
bunders-ernst-2015
Ernst Bunders
Tax Adviser
Loyens & Loeff
Hendrik-van-Waveren
Hendrik Van Waveren
Hamelink & Van Den Tooren
Diana-Maitland
Diana Maitland
Partner - National Leader Transfer Pricing
Deloitte
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