Revision of the United Nations Model Resolution of Tax Treaty Disputes
2005
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SymbolE/C.18/2005/3/Add.1
TitleRevision of the United Nations Model Resolution of Tax Treaty Disputes
AccessFull text: 1STM_revision-of-the-UN-model-E-C18-2005-3-Add1 - PDF ;
Summary
The present paper examines recent evolution as regards mutual agreement procedures. Both the European Union and the OECD have been working on improving dispute resolutions, including in cases of Transfer pricing adjustments. For the first time, the arbitration phase provisioned in the European Convention on Arbitration has been implemented. Within the UN context, it seems useful to improve cooperation and to promote dispute resolutions. Work may result in benchmarking best practices or adopting new methods. Further work is anyway needed to progress on that issue.
1. The EU Arbitration Convention -- 2. The OECD work on improving the resolution of cross-border treaty disputes -- 3. Discussion of arbitration at the last meeting of the Ad Hoc Group of Experts -- 4. Options for future work.
1. The EU Arbitration Convention -- 2. The OECD work on improving the resolution of cross-border treaty disputes -- 3. Discussion of arbitration at the last meeting of the Ad Hoc Group of Experts -- 4. Options for future work.
DateGeneva : UN, 5 Dec. 2005
Description
8 p.