Arbitration Convention
– 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