Cross-border dispute resolution mechanisms have been evolving rapidly in recent years.
The importance of an effective process for enforcing bilateral double tax agreements and for avoiding double tax issues more generally cannot be understated. Two critical tools in this regard are the mutual agreement procedure and arbitration.
The final report on action 14 of the OECD’s base erosion and profit-shifting project focuses on the improvement of tax dispute resolution. Along with the changes that the multilateral instrument makes to article 25(5) of the model convention, the OECD’s work is inspiring international change.
Published in: TAX NOTES INTERNATIONAL – February 25, 2019