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Dispute resolution through mandatory binding arbitration

BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.
 
Implementation of the OECD’s base erosion and profit shifting (BEPS) initiative will reshape many well-established norms of international tax. As these new norms gradually develop an increase is predicted in disputes between tax authorities over taxing rights and the quantification of profits.
 
The BEPS action plan includes two provisions under Action 14 which should help multinationals that regularly find themselves in dispute over international transactions...

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