Commentary

B4.184 Transfer pricing—EU Arbitration Convention

Business tax
Business tax | Commentary

B4.184 Transfer pricing—EU Arbitration Convention

Business tax | Commentary

B4.184 Transfer pricing—EU Arbitration Convention

Following the UK's exit from the EU, no new claims can be accepted under either the EU Arbitration Directive or the EU Arbitration Convention (EUAC) from 1 January 20211. The legislation implementing the EU Arbitration Directive into UK law (SI 2020/51) was revoked by SI 2020/1383. Therefore the commentary below is only relevant for on-going claims.

While the Mutual Agreement Procedure (B4.183) of double tax treaties endeavours to eliminate double taxation, the EU Arbitration Convention2 (EUAC) establishes a procedure to resolve disputes where double taxation occurs between enterprises of different Member States as a result of an upward adjustment of profits of an enterprise of one Member State.

The scope of the EUAC is limited to transfer pricing. The wording is similar to that in many double

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial