Tax treaty arbitration

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Summary

Tax treaty arbitration is a topic that has become more important than ever before. In a post-BEPS world, where tax treaty disputes are expected to increase significantly as a result of the differen...

Tax treaty arbitration is a topic that has become more important than ever before. In a post-BEPS world, where tax treaty disputes are expected to increase significantly as a result of the different measures taken to address treaty abuse, a well-functioning dispute resolution mechanism is key to solving tax treaty disputes. Both the OECD and the European Union took initiatives to improve the mechanisms for dispute resolution in tax matters. The OECD amended article 25 of the OECD Model on the mutual agreement procedure (MAP) and the European Union adopted Council Directive 2017/1852 on tax dispute resolution mechanisms in the European Union. The aim of this book is to provide tax authorities, policymakers, courts and practitioners an overview of the effectiveness of tax treaty arbitration and the approach towards the recent changes in 36 countries. The book comprises 36 national reports from countries across the globe and is the outcome of a conference on tax treaty arbitration that took place from 5 to 7 July 2018 in Rust (Austria). More than 100 experts, including the authors of the national reports, were brought together to discuss recent developments in the field of tax treaty arbitration. A general report highlights the most important findings of the conference.

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