Ian Hyde and Catherine Robins (Pinsent Masons) consider how the dispute resolution measures in the MLI match up to concerns expressed in an earlier ICC survey.
In November 2016 the OECD published the multilateral instrument (MLI) designed to bring into force the double tax treaty aspects of the OECD’s BEPS recommendations relating to hybrid mismatches treaty abuse artificial avoidance of permanent establishments and improving dispute resolution.
Last year the International Chamber of Commerce UK (ICC) conducted a survey in conjunction with Pinsent Masons of the experiences of UK corporates in relation to international tax disputes. In this article we consider how the dispute resolution measures in the MLI match up to the survey responses.
The MLI deals with three areas relating to dispute resolution:
article 16 provides the mechanism to incorporate revised mutual agreement procedure (MAP) wording in...
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Ian Hyde and Catherine Robins (Pinsent Masons) consider how the dispute resolution measures in the MLI match up to concerns expressed in an earlier ICC survey.
In November 2016 the OECD published the multilateral instrument (MLI) designed to bring into force the double tax treaty aspects of the OECD’s BEPS recommendations relating to hybrid mismatches treaty abuse artificial avoidance of permanent establishments and improving dispute resolution.
Last year the International Chamber of Commerce UK (ICC) conducted a survey in conjunction with Pinsent Masons of the experiences of UK corporates in relation to international tax disputes. In this article we consider how the dispute resolution measures in the MLI match up to the survey responses.
The MLI deals with three areas relating to dispute resolution:
article 16 provides the mechanism to incorporate revised mutual agreement procedure (MAP) wording in...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
