This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in ad...This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in advance.As a result of the lack of certainty beforehand,the taxpayer experienced a significant tax correction.According to the author’s perspective,this situation could have been prevented by seeking certainty in advance.展开更多
This paper reviews the literature on the sources of tax uncertainty in tax administration dimension and its effect on taxpayers.It examined two measures taken by the Inland Revenue Board of Malaysia(IRBM)which are the...This paper reviews the literature on the sources of tax uncertainty in tax administration dimension and its effect on taxpayers.It examined two measures taken by the Inland Revenue Board of Malaysia(IRBM)which are the Advance Ruling(AR)and Advance Pricing Arrangement(APA)as dispute prevention and early issue resolution in addressing tax uncertainty.This study found that while the AR and APA have been made and issued,and succeeded in providing tax certainty to the taxpayers,their application is limited.This is reflected in the small number of AR issued and APA that have been made.There is a need to widen the scope by implementing other measures such as the Cooperative Compliance Programme which is already under consideration by IRBM to introduce.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This article summarizes a Dutch court case regarding a business restructuring within a multinational enterprise,where the valuation of the transferred business activities was not confirmed by the tax authorities in advance.As a result of the lack of certainty beforehand,the taxpayer experienced a significant tax correction.According to the author’s perspective,this situation could have been prevented by seeking certainty in advance.
文摘This paper reviews the literature on the sources of tax uncertainty in tax administration dimension and its effect on taxpayers.It examined two measures taken by the Inland Revenue Board of Malaysia(IRBM)which are the Advance Ruling(AR)and Advance Pricing Arrangement(APA)as dispute prevention and early issue resolution in addressing tax uncertainty.This study found that while the AR and APA have been made and issued,and succeeded in providing tax certainty to the taxpayers,their application is limited.This is reflected in the small number of AR issued and APA that have been made.There is a need to widen the scope by implementing other measures such as the Cooperative Compliance Programme which is already under consideration by IRBM to introduce.
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.
