HMRC have published the text of a Memorandum of arrangement which sets out how the UK and New Zealand intend to apply the arbitration provisions in Part 6 of the BEPS Multilateral Instrument. Part 6 deals with mandatory binding arbitration of mutual agreement procedure cases where the respective tax authorities have otherwise not been able to reach agreement. Part 6 is optional and applies only between countries which have expressly chosen to apply it in respect of their covered tax agreements. The MoA came into effect on 11 October 2023.
HMRC have published the text of a Memorandum of arrangement which sets out how the UK and New Zealand intend to apply the arbitration provisions in Part 6 of the BEPS Multilateral Instrument. Part 6 deals with mandatory binding arbitration of mutual agreement procedure cases where the respective tax authorities have otherwise not been able to reach agreement. Part 6 is optional and applies only between countries which have expressly chosen to apply it in respect of their covered tax agreements. The MoA came into effect on 11 October 2023.
