27 October 2016 European Commission announces proposal on double taxation dispute resolution mechanisms in the European Union The European Commission (the Commission) issued a proposal for a Council Directive on Double Taxation Dispute Resolution Mechanisms in the European Union (the Proposed EU Dispute Resolution Directive, the Proposed Directive). The Proposed Directive includes a reinforced mandatory binding dispute resolution mechanism in the European Union. Currently, double taxation dispute resolution in the EU is governed by an inter-governmental Convention, which was signed on July 23, 1990 (the Arbitration Convention). The Proposed Directive builds upon the Arbitration Convention, but broadens the scope to cover additional areas, beyond transfer pricing and allocation of profits to permanent establishment, and provides features to address certain identified shortcomings of the existing process to enhance the enforceability and the effectiveness of the mechanism. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2016-1820 |
