UN: Discussion of Protocol on Dispute Prevention and Resolution
In February 2026 the intergovernmental negotiating committee (INC) continued discussions on the UN Framework Convention on International Tax Cooperation, looking at the early Protocol on tax dispute resolution. Dispute resolution
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Ireland: Revenue issues guidelines on EU tax dispute resolution mechanisms
On 17 July 2023, the Irish Revenue issued eBrief No. 165/23 on European Union (EU) tax dispute resolution mechanisms. Accordingly, Tax and Duty Manual Part 35-02-10 - Guidelines on the European Union (Tax Dispute Resolution Mechanisms) Regulations
See MoreSingapore: IRAS updates e-Tax Guide on DTA to address arbitration procedure
On 23 October 2021, the Inland Revenue Authority of Singapore (IRAS) issued an updated edition of its e-tax guide on “avoidance of double taxation agreements” to add guidance on arbitration provisions in Singapore’s double tax
See MoreGermany publishes Guidance on MAP and arbitration procedures
On 27 August 2021, the Federal Ministry of Finance published guidance on mutual agreement (MAP) and arbitration procedures. The guide explains how to initiate procedures, how to carry out procedures, how to execute agreements, etc. The guidance
See MoreDenmark: OECD publishes latest MLI position on arbitration reservation
On 29 June 2021, the OECD published a document, which contains the consolidated list of reservations and notifications made by the Kingdom of Denmark upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the
See MoreOECD: Profiles for Countries Applying Arbitration under the MLI
On 23 March 2021 the OECD published Arbitration Profiles for 30 jurisdictions that are applying the arbitration provisions in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit
See MoreCanadian mining company wants to resolve its tax dispute with NAFTA arbitration
On 2 March 2021, a publicly traded Canadian mining company (First Majestic Silver), has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in
See MoreBrazil: Government submits a Bill to introduce a special tax arbitration process
On 3 September 2020, the Bill No. 4468/2020, was published in Senate to introduce a special tax arbitration procedure. The Bill proposed that during the time of tax audit, this special tax arbitration process would be available to deal with tax
See MoreAustralia updates guidelines for resolving international tax disputes
The Australian Taxation Office (ATO) has updated the guidelines for the mutual agreement procedure (MAP) and arbitration arrangements. The updated guidelines reflect modifications made (or to be made) in some of Australia’s tax treaties made
See MoreOECD: Draft 2017 updates to the Model Tax Convention
On 11 July 2017 the OECD issued the draft 2017 update of the OECD Model Tax Convention. The changes are to be submitted later in 2017 for approval by the Committee on Fiscal Affairs and the OECD Council. Some parts of the update relate to the
See MoreSpain: EU Court Backs Spanish Tax Breaks For Foreign Acquisitions
Spain has won against European Union for tax breaks intended to help its companies buy stakes in foreign firms, where EU regulators' campaign against tax deals they view as illegal subsidies. The EU court has ruled in Spain's favor regarding
See MoreEU – Pan-European implications of VAT decision on cross-border services
The Court of Justice of the EU recently issued a judgment in a case that may have implications for multinational organizations with either branch operations or head office in EU Member States particularly those entities in the financial services
See MoreECJ: Ruling on Finland’s treatment of capital loss
On 7 November 2013 the European Court of Justice (ECJ) ruled on a question referred to it by the Supreme Administrative Court of Finland in respect of the treatment of a capital loss incurred in another member state. The question put to the ECJ was
See MoreEuropean Court of Justice (ECJ): Taxpayer rights in respect of a request for information
The following questions were put to the European Court of Justice (ECJ) by the Czech Supreme Administrative Court on 4 June 2012 relating to taxpayer rights in respect of a request for information. The European Court of Justice determined that EU
See MoreEU: Advocate General decides in favour of HMRC
The Advocate General has issued an opinion in a case referred to the European Court of Justice (ECJ) by the Danish High Court. The point at issue is whether the scope of Article 1(1) Regulation (EC) No 44/2001 includes an action brought by a State
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