This paper reviews the literature on the sources of tax uncertainty in tax administration dimension and its effect on taxpayers.It examined two measures taken by the Inland Revenue Board of Malaysia(IRBM)which are the...This paper reviews the literature on the sources of tax uncertainty in tax administration dimension and its effect on taxpayers.It examined two measures taken by the Inland Revenue Board of Malaysia(IRBM)which are the Advance Ruling(AR)and Advance Pricing Arrangement(APA)as dispute prevention and early issue resolution in addressing tax uncertainty.This study found that while the AR and APA have been made and issued,and succeeded in providing tax certainty to the taxpayers,their application is limited.This is reflected in the small number of AR issued and APA that have been made.There is a need to widen the scope by implementing other measures such as the Cooperative Compliance Programme which is already under consideration by IRBM to introduce.展开更多
An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of ...An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of China(Hong Kong)has implemented frontend dispute prevention and backend dispute resolution mech-anisms,including advance ruling,advance pricing arrangement(APA)and mutual agreement procedure(MAP)systems.This article explains in detail the requirements and procedures and shares the practical experience relating to advance ruling,APA and MAP in Hong Kong region.展开更多
文摘This paper reviews the literature on the sources of tax uncertainty in tax administration dimension and its effect on taxpayers.It examined two measures taken by the Inland Revenue Board of Malaysia(IRBM)which are the Advance Ruling(AR)and Advance Pricing Arrangement(APA)as dispute prevention and early issue resolution in addressing tax uncertainty.This study found that while the AR and APA have been made and issued,and succeeded in providing tax certainty to the taxpayers,their application is limited.This is reflected in the small number of AR issued and APA that have been made.There is a need to widen the scope by implementing other measures such as the Cooperative Compliance Programme which is already under consideration by IRBM to introduce.
文摘An effective mechanism for dispute prevention and resolution is im-portant to both tax administrations and taxpayers in achieving tax certainty.The Hong Kong Special Administrative Region of the People’s Republic of China(Hong Kong)has implemented frontend dispute prevention and backend dispute resolution mech-anisms,including advance ruling,advance pricing arrangement(APA)and mutual agreement procedure(MAP)systems.This article explains in detail the requirements and procedures and shares the practical experience relating to advance ruling,APA and MAP in Hong Kong region.
