Authors: Piergiorgio Valente and Caterina Alagna
Multinational companies are increasingly exposed to the risk of double taxation due to transfer pricing-related tax adjustments following assessments by Tax Authorities.
The use of specific procedures to solve international tax disputes, in particular those described in Art. 25 of the OECD Model Tax Convention and the Arbitration Convention 90/436/EEC, requires an accurate evaluation of they relate to internal administration and jurisdiction processes.
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