The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of ...The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of a dispute prevention and resolution framework for the GloBE rules faces significant challenges.This article offers two possible options for an effective dispute prevention and resolution mechanism:a model based on reciprocal domestic legislations and the multilateral convention model.展开更多
An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of ...An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of China(Hong Kong)has implemented frontend dispute prevention and backend dispute resolution mech-anisms,including advance ruling,advance pricing arrangement(APA)and mutual agreement procedure(MAP)systems.This article explains in detail the requirements and procedures and shares the practical experience relating to advance ruling,APA and MAP in Hong Kong region.展开更多
Tax certainty is key for both businesses and governments to optimise investments and economic progress.This article shares the experience of the Inland Revenue Authority of Singapore and the approaches taken to provid...Tax certainty is key for both businesses and governments to optimise investments and economic progress.This article shares the experience of the Inland Revenue Authority of Singapore and the approaches taken to provide a more certain tax environment for taxpayers.展开更多
文摘The successful implementation of the Global Anti-Base Erosion(GloBE)rules on a global scale cannot be achieved without an international effective dispute prevention and resolution mechanism.However,the development of a dispute prevention and resolution framework for the GloBE rules faces significant challenges.This article offers two possible options for an effective dispute prevention and resolution mechanism:a model based on reciprocal domestic legislations and the multilateral convention model.
文摘An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of China(Hong Kong)has implemented frontend dispute prevention and backend dispute resolution mech-anisms,including advance ruling,advance pricing arrangement(APA)and mutual agreement procedure(MAP)systems.This article explains in detail the requirements and procedures and shares the practical experience relating to advance ruling,APA and MAP in Hong Kong region.
文摘Tax certainty is key for both businesses and governments to optimise investments and economic progress.This article shares the experience of the Inland Revenue Authority of Singapore and the approaches taken to provide a more certain tax environment for taxpayers.
