Elimination of the International Double Taxation
When a tax inspection ends with a Transfer Pricing adjustment in a taxpayer’s related transactions, double taxation automatically occurs if the situation is not also regularised (correlative adjustment) in the other affected related entity, especially if it is located in another jurisdiction
At Mazars we present and assist taxpayers in dispute resolution proceedings for the application of the EU Directive (1852/2017), in the amicable procedure regime of agreements for the elimination of double taxation or MAPs and in the preparation of international arbitration agreements.
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