Advance rulings on the application of tax treaties

• Autores: Federico Balbiano Colcavagno
• Localización: European taxation, ISSN 0014-3138, Vol. 47, Nº. 8-9, 2007, págs. 398-406
• Idioma: inglés
• Texto completo no disponible (Saber más ...)
• Resumen

  • The concept behind this article is derived from the practice of many states that have adopted advance agreements to determine the value of operations within a group of companies. The question considered by the author is whether or not and how such advance agreements could be used for the purpose of resolving in advance possible conflicts between states with regard to all the possible international tax implications, especially in respect of tax treaties.