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U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941)

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U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries discusses the competent authority functions and procedures of Australia, Canada, France, Mexico, The Netherlands, and the United Kingdom.

Each chapter initially focuses on the mutual agreement procedure that is available to taxpayers subject to double taxation, and in that connection discusses such topics as the basic procedure for requesting competent authority relief, statute of limitations issues, the role of Appeals (if any), the small case procedure (if any), interest on deficiencies and refunds, and the possibility of arbitration. If a country also has procedures for Advance Pricing Agreements, those are also considered in this Portfolio.

Each chapter of U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries then discusses the procedures relating to consultation between competent authorities regarding the interpretation or application of an income tax treaty, exchange of information, and assistance in collection. With respect to exchange of information, each chapter also considers procedures under any tax information exchange agreements to which the country is a party.

U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries allows you to benefit from:

  • Hundreds of hours of original research on specific tax planning topics from leading practitioners in this area
  • Invaluable practice documents including tables, charts and lists
  • Plain-English guidance from world-class experts
  • Real-world and in-depth analysis that lets you explore various options
  • Time-saving access to relevant sections of tax laws, regulations, court cases, IRS documents and more.
  • Alternative approaches to both common and unique tax scenarios

This Portfolio is part of the Foreign Income Portfolios Library, a comprehensive series containing more than 90 Portfolios, which covers critical transactions and issues in international taxation. This highly-regarded resource service offers commentary on a wide range of foreign income topics including: Foreign Tax Credit, Business Operations in more than 40 foreign countries, Branch ProfitsTax, Source of Income Rules, Subpart F (Controlled Foreign Corporations), Foreign Partnerships and Partners, Transfer Pricing, and more.

 

 

Detailed Analysis

Chapter 1 - AUSTRALIA

1:I. Introduction

1:II. Australian Competent Authority

A. Functions in General

B. Identification

1:III. Mutual Agreement Procedure in Taxpayer Cases

A. Treaty Provisions on Mutual Agreement

1. OECD Model

2. Australian Income Tax Treaties

B. Background

1. Historical Background

2. Powers of Competent Authorities in MAP

3. Types of Cases

a. Allocation Cases

b. Nonallocation Cases

4. Program Evaluation

5. Self-Adjustment Not Permitted

C. The Process

1. Sources

2. Taxes and Issues Covered

3. Who Can Apply?

4. Timing of Requests

a. In General

b. Statute of Limitations and Other Procedural Limitations

5. Role of ATO Transfer Pricing Specialists

6. The Role of Appeals

7. Pre-Filing and Post-Filing Conferences

8. Presentation of Case

9. Small Case Procedure

10. Justification of Claim

11. Denial of Requests

12. Processing of MAP Cases

a. Stages of Procedure in the ATO

(1) Examination of Taxpayer's Claim

(2) Preparation of ATO Position

(3) Negotiation

(4) Decision on Taxpayer's Claim

b. Withdrawal of MAP Request

c. Court Proceedings

13. Confidentiality in Competent Authority Proceedings

a. Confidentiality of Returns and Return Information

b. Communication of Taxpayer Information Between Competent Authorities

c. Nondisclosure by Competent Authorities

14. Interest and Penalties

15. Remission of General Interest Charge Accrued During MAP

16. Payment of Tax During MAP

17. Repatriation of Funds After Reallocation

D. Arbitration

1. OECD Position

2. Need for Arbitration

1:IV. Advance Pricing Arrangements

A. Introduction

B. Prelodgement Meeting

C. Preparation and Lodgement

D. Evaluation of APA Application

E. Documentation Requirements

F. Liaison with Other Competent Authority

G. Small Business APAs

H. Compensating Adjustments

I. Time Frame

J. Withdrawing from APA Process

1:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application

1:VI. Exchange of Information

A. Exchange of Information Under International Agreements

B. Exchange of Information Under Income Tax Treaties

1. Liaison with Other Tax Administrations

2. Types of Exchanges

a. Exchanges Regarding Changes in Tax Laws

b. Automatic Exchange of Information

c. Spontaneous Exchange of Information

d. Specific Requests for Information

e. Industry-Wide and Issue-Specific Exchange of Information

3. Simultaneous Examination Programs

a. Definition

b. Specific Objectives

c. Procedures

d. Disclosure of Information

4. Responding to Specific Information Requests Under Tax Treaties

a. Specificity of Request

b. Use of Revenue Powers to Obtain Information

c. Mutuality Clause

5. Business Secrets

6. Restrictions on Use and Disclosure of Exchanged Information

1:VII. Assistance in Collection

Chapter 2 -CANADA

2:I. Introduction

2:II. Canadian Competent Authority

A. Functions in General

B. Legislative Framework

C. Identification

D. Taxpayer Cases

2:III. Mutual Agreement Procedure in Taxpayer Cases

A. Treaty Provisions on Mutual Agreement

B. Background

C. The Process

1. Sources

2. Taxes and Issues Covered

3. Who Can Apply?

4. Timing of Requests

5. Unilateral Relief

6. Role of Appeals

7. Pre-Filing and Post-Filing Conferences

8. Information Required

9. Protective Measures

10. Small Case Procedure

11. Simultaneous Appeals Procedure

12. Denial of Requests

a. Appeal Rights

b. De Minimis Amounts

13. Processing of MAP Cases

a. Withdrawal of MAP Request

b. Effect on Domestic Proceedings

c. Court Proceedings

14. Confidentiality in Competent Authority Proceedings

15. Interest on Deficiencies and Refunds, and Penalties

16. Repatriation of Funds After Reallocation

17. Accelerated Competent Authority Procedure

D. Arbitration

E. Mandatory Use of MAP to Protect Canadian Foreign Tax Credits

F. Application to Provinces and Territories

2:IV. Advance Pricing Arrangements

Introductory Material

A. Circular Contents

B. Pre-Filing Meetings

C. Processing an APA Request

D. APA Submission Content

E. Use, Disclosure, and Protection of Information

F. Renewal

2:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application

2:VI. Exchange of Information

A. In General

1. General History

2. Legislative Procedures for Accessing Foreign-Based Information

B. Exchange of Information Under Income Tax Treaties

1. Scope of Treaty Provisions

a. Taxpayers Covered

b. Taxes Covered

c. Nature of Information

2. Types of Exchanges

a. Automatic Exchange of Information

b. Spontaneous Exchange of Information

c. Specific Requests for Information

3. Simultaneous Examination Programs

4. Restrictions on Use and Disclosure of Exchanged Information

2:VII. Assistance in Collection

Introductory Material

A. Accepted Revenue Claims

B. Citizenship Rule

Chapter 3 -FRANCE

3:I. Introduction

3:II. French Competent Authority

3:III. Mutual Agreement Procedure for Taxpayer Cases

A. Background

B. The Process

1. Scope of the MAP

2. Persons Eligible to Invoke the MAP

3. Procedure to Invoke the MAP

C. Arbitration

1. In General

2. Arbitration Commission and Procedure

3:IV. Advance Pricing Agreements

Introductory Material

A. APA Procedure

B. Content of APA

C. Advantages and Disadvantages of an APA

3:V. Exchange of Information

Chapter 4 -MEXICO

4:I. Introduction

4:II. Mexican Competent Authority

A. Functions in General

B. Identification

4:III. Mutual Agreement Procedure in Taxpayer Cases

A. Treaty Provisions on Mutual Agreement

1. OECD Model

2. Mexico's Income Tax Treaties

B. Background

1. Historical Background

2. Powers of Competent Authorities in a MAP

3. Types of Cases

a. Allocation Cases

b. Nonallocation Cases

4. Program Evaluation

5. Self-Help

C. The Process

1. Taxes and Issues Covered

2. Who Can Apply?

3. Timing of Requests

a. In General

b. Statute of Limitations and Other Procedural Limitations

4. Role of Appeals

5. Pre-Filing and Post-Filing Conferences

6. Information Required

7. Protective Measures

8. Small Case Procedure

9. Simultaneous Appeals Procedure

10. Denial of Requests

a. Basis for Denial

b. Appeal Rights

c. De Minimis Amounts

11. Processing of MAP Cases

a. Withdrawal of MAP Request

b. Effect on Domestic Proceedings

c. Court Proceedings

12. Confidentiality in Competent Authority Proceedings

a. Confidentiality of Returns and Return Information

b. Communication of Taxpayer Information Between Competent Authorities

c. Nondisclosure by Competent Authorities

13. Interest on Deficiencies and Refunds

14. Penalties

15. Repatriation of Funds After Reallocation

16. Accelerated Competent Authority Procedure

D. Arbitration

1. Background - Mexican Treaties

2. Arbitration Procedures Under Other Mexican International Agreements

3. Need for Arbitration

E. Protecting the Availability of Mexican Foreign Tax Credits

4:IV. Advance Pricing Agreements

4:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application

A. In General

B. Scope of Consultation Provisions

C. Use of Consultation Procedure

D. Legal Effect of Consultations

4:VI. Exchange of Information

A. Exchange of Information Outside of International Agreements

B. Exchange of Information Under Income Tax Treaties

1. Scope of Treaty Provisions

2. Types of Exchanges

a. Exchanges Regarding Changes in Tax Laws

b. Automatic Exchange of Information

c. Spontaneous Exchange of Information

d. Specific Requests for Information

e. Industry-Wide Exchange of Information

3. Simultaneous Examination Programs

a. General Purpose

b. Disclosure of Information

4. Responding to Specific Information Requests Under Tax Treaties

a. Use of Revenue Powers to Obtain Information

b. Mutuality Clause

5. Business Secrets

6. Restrictions on Use and Disclosure of Exchanged Information

C. Exchange of Tax Information Agreements

1. Taxes Covered

2. Types of Exchanges

3. Agreement Provisions

4. Exchange of Information Programs

5. Limitations in Agreements

4:VII. Assistance in Collection

Chapter 5 - THE NETHERLANDS

5:I. Introduction

5:II. The Dutch Competent Authority

5:III. Mutual Agreement Procedure in Taxpayer Cases

A. The Process

1. Who Can Apply?

2. Corresponding Adjustments

3. Issues Covered in a MAP

4. Form and Content of Request

5. Timing of Requests and Limitations

6. Pre-Filing Meeting/Taxpayer Participation

7. Concurrence of Objection and Appeal Procedure and the MAP

8. Extension for Payment, Transfer Pricing Adjustments, Interest Charges, and Penalties

9. Secondary Adjustments

B. Netherlands-U.S. Administrative Procedures

C. Arbitration

5:IV. Advance Pricing Agreements

Introductory Material

A. Organization

B. Unilateral versus Bilateral APAs

C. Scope of APAs

D. Duration

E. Retroactive Effect

F. APA Request

G. Pre-Filing Meeting

H. Case Management Plan

I. Small Business APA

5:V. Exchange of Information

Chapter 6 - THE UNITED KINGDOM

6:I. Introduction

6:II. U.K. Competent Authority

A. Functions in General

B. Identification

6:III. Mutual Agreement Procedure in Taxpayer Cases

A. Treaty Provisions on Mutual Agreement

1. OECD Model

2. U.K. Income Tax Treaties

B. Background

1. Historical Background

2. Powers of Competent Authorities in a MAP

3. Types of Cases

a. Allocation Cases

b. Nonallocation Cases

4. Program Evaluation

5. Self-Help Alternative

C. The Process

1. Sources

2. Taxes and Issues Covered

3. Who Can Apply?

4. Timing of Requests

a. In General

b. Statute of Limitations and Other Procedural Limitations

(1) In General

(2) Treaty Provisions

(3) Opening Barred Assessment Periods

(4) Keeping Years Open

5. Unilateral Relief

6. The Role of Appeals

7. Pre-Filing and Post-Filing Conferences

8. Information Required

9. Protective Measures

10. Small Case Procedure

11. Simultaneous Appeals Procedure

12. Denial of Requests

a. Basis for Denial

b. Appeal Rights

c. De Minimis Amounts

13. Processing of MAP Cases

a. Stages of Procedure in Revenue & Customs

b. Withdrawal of MAP Request

c. Effect on Domestic Proceedings

d. Court Proceedings

14. Confidentiality in Competent Authority Proceedings

a. Confidentiality of Returns and Return Information

b. Communication of Taxpayer Information Between Competent Authorities

c. Nondisclosure by Competent Authorities

15. Interest on Deficiencies and Refunds

16. Penalties

17. Repatriation of Funds After Reallocation

18. Accelerated Competent Authority Procedure

D. Arbitration

1. Background - U.K. Treaties

2. Arbitration Procedures Under Other U.K. International Agreements

3. Need for Arbitration

E. Protecting the Availability of U.K. Foreign Tax Credits

F. Application to U.K. Dependencies

6:IV. Advance Pricing Agreements

6:V. Consultation Between Competent Authorities Regarding Treaty Interpretation or Application

A. In General

B. Scope of Consultation Provisions

C. Use of Consultation Procedure

D. Legal Effect of Consultations

6:VI. Exchange of Information

A. In General

1. Exchange of Information Outside of International Agreements

2. Exchange of Information Under International Agreements

B. Exchange of Information Under Income Tax Treaties

1. Scope of Treaty Provisions

a. Taxpayers Covered

b. Taxes Covered

c. Nature of Information

2. Types of Exchanges

a. In General

b. Exchanges Regarding Changes in Tax Laws

c. Automatic Exchange of Information

d. Spontaneous Exchange of Information

e. Specific Requests for Information

f. Industry-Wide and Issue-Specific Exchange of Information

3. Simultaneous Examination Programs

a. General Purpose

b. Specific Objectives

c. Procedures

d. Disclosure of Information

4. Responding to Specific Information Requests Under Tax Treaties

a. Specificity of Request

b. Use of Revenue Powers to Obtain Information

c. Mutuality Clause

5. Business Secrets

6. Restrictions on Use and Disclosure of Exchanged Information

a. Use for Tax Purposes Only

b. Restrictions on Disclosure

c. Nondisclosure to Parliament

d. Nondisclosure to Third Countries

C. Tax Information Exchange Agreements

D. Exchange of Information Under Other International Agreements

1. European Arbitration Convention

2. Mutual Assistance Directive

6:VII. Assistance in Collection

Working Papers

Table of Worksheets

Worksheet 10 Chart Describing Articles 9 and 25 of Canadian Income Tax Treaties

Worksheet 11 Sample Article XIII (8) Agreement

Worksheet 12 Sample Article XXIX (5) Agreement

Worksheet 13 Sample Article XXIX B (5) Agreement

Worksheet 50 Administrative Arrangement for Implementation of Mutual Agreement Procedure Under U.S.-U.K. Income Tax Convention

Bibliography

OFFICIAL

Legislation and Statutes:

Chapter 1: Australia

Chapter 2: Canada

Chapter 4: Mexico

Chapter 5: The Netherlands

Chapter 6: The United Kingdom

Cases:

Rulings:

Chapter 1: Australia

Chapter 2: Canada

Chapter 3: France

Chapter 4: Mexico

Chapter 5: The Netherlands

Chapter 6: The United Kingdom

UNOFFICIAL

Model Treaties and Other Guidelines:

Books and Reports:

2007

2008

2009

Sandra M. Goldberg
Sandra Goldberg, LL.B., University of Ottawa, 1982; Associate Partner, Deloitte & Touche LLP, Ottawa, Ontario; member Law Society of Upper Canada since 1984, Canadian Tax Foundation, International Fiscal Association; speaker on transfer pricing issues; author, articles on transfer pricing, competent authority and permanent establishments; named in Euromoney’s 2008 list of World’s Leading Transfer Pricing Advisors. 
Ronald E. Haigh
Thijs J. M. Heijenrath
Thijs Heijenrath, University of Tilburg, Master’s in tax law; certified tax advisor and member of the Dutch Tax Advisors Association (NOB); member of the Global Transfer Pricing Strategy board of Deloitte;  international tax partner with Deloitte Belastingadviseurs BV, Netherlands affiliate of Deloitte Touche Tohmatsu, based in Rotterdam. Mr. Heijenrath leads Deloitte's Transfer Pricing / Tax-Aligned Supply Chain group in the Netherlands and is an active member of the Global Transfer Pricing Strategy board of Deloitte. 
David Lewis
David Lewis, senior consultant to Deloitte Touche Tohmatsu's specialist Transfer Pricing group in Australia; former ATO Assistant Commissioner and Competent Authority.
Gianmarco Monsellato
Gianmarco Monsellato; graduate of the HEC Group, International Management School France; recognized as “Lead Tax Adviser” and “Lead Transfer Pricing Advisor” in all Euromoney Legal Media Group Surveys. Co-founder of the Transfer Pricing worldwide Deloitte team, his service line has been quoted n°1 Transfer Pricing Team in France, by the International Tax Review; co-author of the first French book on transfer pricing: Les prix de Transfert; wrote the French chapter in Transfer Pricing – an International Guide; author of numerous articles on international tax and transfer pricing in French and international reviews; is a member of the global transfer pricing task force of the International Chamber of Commerce; member of the IFA; member of the French-US Chamber of Commerce; has substantial experience in strategic tax planning, tax controversies, Advance Transfer Pricing Agreements and Competent Authority Procedures; is currently the Managing Partner (CEO) of Taj, an international tax and law firm in France, member of Deloitte Touche Tohmatsu and advises leading European, Japanese, Korean and US multinational companies in transfer pricing and international tax strategies.
Ricardo Gonzales Orta
Ricardo Gonzalez Orta; graduate of the Universidad Iberoamericano; has significant experience in transfer pricing matters and coordinates the Deloitte Mexico and Latin America region Transfer Pricing practices; spent eight years in a number of top executive posts with the Ministry of Finance (Secretaría de Hacienda y Crédito Público -SHCP-) and the Tax Administration Service (Servicio de Administración Tributaria -SAT-), most recently as Director General of Tax Policy and, as Director General of International Fiscal Affairs, in these positions he was in charge of Mexico's tax and customs policy and the negotiation of double taxation treaties; is a frequent speaker in different domestic and international forums; writes periodically on Mexican tax and transfer pricing issues in the Tax Management International Journal; is currently a partner at Galaz, Yamazaki, Ruiz Urquiza SC, Deloitte Touche Tohmatsu´s Mexico affiliate, where he advises multinational companies on tax-related matters, including structuring new businesses, acquisitions, reorganizations, joint ventures, double taxation issues, and transfer pricing.
Jean-Luc Truchi
Gary Zed