Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O-Z) (Portfolio 6895)

Description

The Tax Management Portfolio, Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O–Z), No. 6895, discusses the competent authority functions and procedures of Russia, Spain, Sweden, Switzerland and the United Kingdom. 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., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O–Z).

This Portfolio may be cited as Alekseyev, et al., 6895 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (O–Z).

Table of Contents

140:I. Introduction
140:II. The Competent Authority of the Russian Federation
140:III. Mutual Agreement Procedure for Taxpayer Cases
140:IV. Advance Transfer Pricing Agreements
140:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
140:VI. Exchange of Information
140:VII. Assistance in Tax Collection
150:I. Introduction
150:II. The Competent Authority in Spain
150:III. The Mutual Agreement Procedure for Taxpayer Cases
150:IV. Advance Pricing Agreements
150:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
150:VI. Exchange of Information
155:I. Introduction
155:II. The Competent Authority of Sweden
155:III. The Mutual Agreement Procedure for Taxpayer Cases
155:IV. Advance Pricing Agreements
155:V. Exchange of Information
160:I. Introduction
160:II. The Swiss Competent Authority
160:III. The Mutual Agreement Procedure in Taxpayer Cases (MAP)
160:IV. Advance Pricing Agreements
160:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
160:VI. Exchange of Information: Administrative vs. Judicial Assistance
160:VII. Assistance in Tax Collection
175:I. Introduction
175:II. U.K. Competent Authority
175:III. Mutual Agreement Procedure in Taxpayer Cases
175:IV. Advance Pricing Agreements
175:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application
175:VI. Exchange of Information
175:VII. Assistance in Tax Collection