The new directive makes important changes to the regime for resolving double taxation disputes, write Liesl Fichardt and Chintan Chandrachud (Quinn Emanuel Urquhart & Sullivan).
What has happened?
In October 2016 the Commission announced a set of corporate tax reforms including a proposed Directive on double taxation dispute resolution mechanisms in the EU. Following this the Directive was adopted in October 2017 and must be implemented by member states by 30 June 2019 with complaints under the dispute resolution procedure being received from 1 July 2019.
What is the background?
Double taxation occurs when different member states tax the same income or capital in the hands of the same taxpayer and for the same period. Disputes arise between taxpayers and member states when agreements (such as bilateral tax treaties) providing for the elimination of double taxation are applied or interpreted inconsistently by...
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The new directive makes important changes to the regime for resolving double taxation disputes, write Liesl Fichardt and Chintan Chandrachud (Quinn Emanuel Urquhart & Sullivan).
What has happened?
In October 2016 the Commission announced a set of corporate tax reforms including a proposed Directive on double taxation dispute resolution mechanisms in the EU. Following this the Directive was adopted in October 2017 and must be implemented by member states by 30 June 2019 with complaints under the dispute resolution procedure being received from 1 July 2019.
What is the background?
Double taxation occurs when different member states tax the same income or capital in the hands of the same taxpayer and for the same period. Disputes arise between taxpayers and member states when agreements (such as bilateral tax treaties) providing for the elimination of double taxation are applied or interpreted inconsistently by...
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:
