– see also Transfer pricing

Adjustment procedure

Commentary – Schwarz on Tax Treaties ¶28-350

Advisory Commission

Commentary – Schwarz on Tax Treaties ¶28-350

Arm's length standard

Commentary – Schwarz on Tax Treaties ¶28-150

Choice of forum

Commentary – Schwarz on Tax Treaties ¶28-400

Code of conduct

Commentary – Schwarz on Tax Treaties ¶28-350

Costs

Commentary – Schwarz on Tax Treaties ¶28-350

Determinations, giving effect to

Legislation/Regulatory – TIOPA2010 s. 127
HMRC Guidance – INTM423070

Disclosures under

Legislation/Regulatory – TIOPA2010 s. 128

Elimination of double taxation

Commentary – Schwarz on Tax Treaties ¶28-250

Generally

Commentary – Schwarz on Tax Treaties ¶10-150 ; Schwarz on Tax Treaties ¶22-200 ; Schwarz on Tax Treaties ¶27-500 ; Schwarz on Tax Treaties ¶28-000

Information

Commentary – Schwarz on Tax Treaties ¶28-350

Initial resolution

Commentary – Schwarz on Tax Treaties ¶28-350

Meaning

Legislation/Regulatory – TIOPA2010 s. 126
HMRC Guidance – INTM423010

Mutual agreement procedure

Commentary – Schwarz on Tax Treaties ¶28-350

Participation in management, control or capital

Commentary – Schwarz on Tax Treaties ¶28-200

Penalty proceedings

Commentary – Schwarz on Tax Treaties ¶28-450

Role of

Commentary – Schwarz on Tax Treaties ¶28-500

Scope of

Commentary – Schwarz on Tax Treaties ¶28-050

Significance of

Commentary – Schwarz on Tax Treaties ¶28-500

Taxes covered

Commentary – Schwarz on Tax Treaties ¶28-100

Three-year time limitation rule

Commentary – Schwarz on Tax Treaties ¶28-300