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Overview
This volume in the Seminar Series contains the proceedings of the 47th IFA Congress Seminar dealing with the issue of tax treaty arbitration. Among the topics covered by the participating panellists were recent developments in tax treaty arbitration, international control mechanisms, key elements of independent arbitration procedures and the European Tax Arbitration Convention.
The articles contained in this volume are an expanded version of the speeches held by the Seminar's international group of panellists. The EC Arbitration Convention, Treaty Articles making reference to Arbitration and the ICC Resolution have been included in the book.
Synopsis
This volume of the IFA Congress Seminar Series is centered on corporate tax on distributions and contains the reports that were presented at an IFA Congress Seminar held in Florence in 1993 entitled Corporate Tax on Distributions: Equalization Tax .
Booknews
Presents the material that was prepared by a panel of international tax experts to address the subject. They consider not only the technical aspects of secondary adjustments, but also the underlying philosophical question of whether there should be any at all and if so what appropriate limitations might be. They discuss a labyrinth of potential adjustments that could flow from the primary transfer pricing adjustment, as well as set-offs and corresponding adjustments. No index. Annotation c. Book News, Inc., Portland, OR (booknews.com)