Article summary
HMRC has said it expects to lay the Double Taxation Dispute Resolution (EU) Regulations 2020, to implement the new EU arbitration directive in UK law shortly. HMRC consulted between July and August 2019 on a draft of the 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 six months.
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