TY - JOUR
T1 - Sull’inquadramento sistematico e sulla natura giuridica degli accordi preventivi per le imprese con attività internazionale e sulla loro estensibilità all’IVA
AU - Perrone, Antonio
PY - 2019
Y1 - 2019
N2 - This essay will address three specific issues concerning the new institute about previous agreements for international businesses. The first issue focus on the internal structure, which, according to the most part of scholars, is not configurable as a private agreement, but as a joint exercise of tax assessment power. The second concern the relationship between the new institute and the traditional domestic rulings. The third asks if it is possibleto extend agreement effects also to VAT, particularly to the permanent establishment. The way chosen to address these issues involves a juxtaposition between the new institute and the Mutual Agreement Procedure (MAPs), with the aim to find possible common points.
AB - This essay will address three specific issues concerning the new institute about previous agreements for international businesses. The first issue focus on the internal structure, which, according to the most part of scholars, is not configurable as a private agreement, but as a joint exercise of tax assessment power. The second concern the relationship between the new institute and the traditional domestic rulings. The third asks if it is possibleto extend agreement effects also to VAT, particularly to the permanent establishment. The way chosen to address these issues involves a juxtaposition between the new institute and the Mutual Agreement Procedure (MAPs), with the aim to find possible common points.
UR - http://hdl.handle.net/10447/375418
M3 - Article
VL - 29
SP - 387
EP - 419
JO - RIVISTA DI DIRITTO TRIBUTARIO
JF - RIVISTA DI DIRITTO TRIBUTARIO
SN - 1121-4074
ER -