MNCs turn to tax treaties to settle cross-border disputes faster
New Delhi, June 10 -- India's top law firms are seeing a significant rise in mandates from multinational companies (MNCs) seeking to resolve cross-border tax disputes through the mutual agreement procedure (MAP), a treaty-based dispute resolution mechanism, as businesses increasingly turn away from lengthy litigation in favour of negotiated settlements.
Unlike conventional litigation before tribunals and courts, the process relies on negotiations between competent authorities of treaty partners.
MAP, once largely used for transfer pricing disputes, is now increasingly being explored for issues such as permanent establishment, profit attribution, royalties, withholding tax, and treaty disputes. Technology, manufacturing, pharma, financia...
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