On The Basis Of Mutual Agreement
His advocacy and promise that we will listen to each other and learn from each other and interact on the basis of mutual interests and respect. 1. The POP procedure applies both in the case of double taxation and in the absence of double taxation, which is contrary to the double taxation provisions of the convention, since the taxes at issue do not comply with treaty standards (point 13); Patients are then treated at the clinic on the basis of mutual agreement during this meeting and are encouraged to rejuvenate their use of substances before being admitted to treatment. But in recent days, the United States, Canada and Mexico have asked the International Civil Aviation Organization, an influential Un body, to adopt a resolution that countries that wish to “establish an emissions trading system for aircraft operators of other states parties” do so only “on the basis of mutual agreement.” Taxpayers` rights are of the utmost importance in the context of fundamental changes in the regulation of international tax relations, which are determined by the need to combat global tax evasion. These changes create a high degree of uncertainty among taxpayers who, due to the decline in investment and entrepreneurial activities, could have a negative impact on the economic development of developing countries in particular. Therefore, modern states should offer a high degree of effectiveness in dispute resolution mechanisms, including the Mutual Agreement Procedure (POP). This is the procedural mechanism for taxpayers not to resolve their tax cases in accordance with the provisions of the double taxation agreements, by launching communication between the competent authorities of the contracting states that have entered into double taxation agreements. On the basis of the analysis of the pros and cons of POPs, it could be seen that their attractiveness to taxpayers is not as obvious, as some safeguards, such as the right to confidentiality or the right to be informed of the negotiation process between the competent authorities, are not obvious. In this context, the success of the international community is only partial, as it is difficult to find a common denominator and differences of interest at the global level. At the same time, the EU example shows that regional cooperation could be essential to improving taxpayers` rights under the POP, which could be taken into account by the BRICS in their attempts to improve tax dispute settlement mechanisms.
At the same time, there is no consensus among members of the international community on the issue of the concrete package of tax rights in the POP process, other than the right to initiate POPs. It is also absent at the researcher level. Nevertheless, the example of cooperation between EU Member States in improving dispute settlement on the basis of POPs shows that the list of taxpayers` rights has a real chance of being expanded at the regional level because of the similarity of the economic interests of cooperating states. By adopting the Council`s 2017/1852/EC Directive of 10 October 2017 on tax dispute settlement mechanisms in the EU, EU Member States have extended the taxpayer package under the POP on the basis of their double taxation agreements. The United States, Canada and Mexico first asked the United Nations aviation body to pass a resolution that states that countries that wanted to set up an emissions trading system for airlines in other countries only do so “on the basis of mutual agreement.” Therefore, the protection of taxpayers` claims is to expand the list of their rights further than it currently is under POPs on the basis of the BRICS double taxation conventions. At least these rights should be the right to be informed of the negotiation process between the competent authorities, the right to be informed of all documents submitted by the competent authorities in the context of the map procedure (except those for which a case of confidentiality