Settlement of Disputes in Tax Treaty Law

In a world of tight legal and economic networks, tax disputes are on the increase. Until recently, mutual agreement procedures have virtually been the only means of settling such tax disputes amicably. In practice, mutual agreement procedures have not always proved satisfactory. The Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises, can serve as an alternative dispute settlement vehicle. However, only transfer pricing disputes fall within the applicability of this EU Convention and its geographic scope is restricted to EU territory. As part of their present treaty policy, some countries have therefore added arbitration clauses to newly negotiated tax treaties. These arbit

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Settlement of Disputes in Tax Treaty Law

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