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Arbitration under double taxation agreements with relevance to UK Law? |
Arbitration under double taxation agreements with relevance to UK Law? Is this what you are looking for? The Arbitration Convention may be used as an alternative procedure to the mutual agreement procedure under the UK's Double Taxation Agreements in certain cases of double taxation arising from transfer pricing adjustments. The Tax Bulletin article "The Mutual Agreement Procedure in UK Double Taxation Conventions" (Issue 25 October 1996) indicated that further guidance would be provided, and this article provides that guidance. Although the article necessarily expresses the UK's interpretation of the Arbitration Convention, the Inland Revenue has discussed the implementation of the Arbitration Convention with other contracting states and believes that the interpretations expressed are shared by other states. The Inland Revenue expects that such discussion will continue in the light of greater practical experience in implementing the Arbitration Convention. The UK, along with the other member states of the European Union, is a signatory to the Arbitration Convention ("Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises" 90/463/EEC) -- referred to in the rest of this article as "the Convention". The Convention came into force on 1 January 1995 for an initial period of five years. (The process of extending the provision of the Convention to the new member states -- Austria, Finland, and Sweden -- is currently under way but ratification is not yet complete). More on this website: http://www.hmrc.gov.uk/bulletins/tb31.ht... Source(s): More on this website: http://www.hmrc.gov.uk/bulletins/tb31.ht... |
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