HMRC expects shortly to lay the Double Taxation Dispute Resolution (EU) Regulations 2020, to implement the new EU arbitration directive in UK law. HMRC consulted between July and August 2019 on a draft of these regulations.
The directive, which will apply to disputes involving tax years beginning on or after 1 January 2018, introduces a mutual agreement procedure for resolving disputes within two years, after which an advisory commission can be set up to deliver an opinion within 6 months.
A tax information and impact note (bit.ly/2Rgn2V3) sets out the background to the directive and regulations.
The arbitration directive is intended to address certain shortcomings identified during a 2015 review of the workings of the Union Arbitration Convention.
HMRC expects shortly to lay the Double Taxation Dispute Resolution (EU) Regulations 2020, to implement the new EU arbitration directive in UK law. HMRC consulted between July and August 2019 on a draft of these regulations.
The directive, which will apply to disputes involving tax years beginning on or after 1 January 2018, introduces a mutual agreement procedure for resolving disputes within two years, after which an advisory commission can be set up to deliver an opinion within 6 months.
A tax information and impact note (bit.ly/2Rgn2V3) sets out the background to the directive and regulations.
The arbitration directive is intended to address certain shortcomings identified during a 2015 review of the workings of the Union Arbitration Convention.
