HMRC has added the Memorandum of Understanding between the UK and Isle of Man, on the article 25 arbitration procedure in unresolved disagreement cases involving double taxation, to its tax treaty pages. Article 25 (based on article 25 of the OECD Model Tax Convention) sets out the framework for the mutual agreement procedure, including the option of arbitration where the competent authorities have not been able to reach agreement.
HMRC has added the Memorandum of Understanding between the UK and Isle of Man, on the article 25 arbitration procedure in unresolved disagreement cases involving double taxation, to its tax treaty pages. Article 25 (based on article 25 of the OECD Model Tax Convention) sets out the framework for the mutual agreement procedure, including the option of arbitration where the competent authorities have not been able to reach agreement.
