Improving on the old mechanism, the new one, proposed in October 2017 and applicable to claims submitted after July 1st, 2019, features enforceable obligations for the Member States to agree on a binding solution, in a standard period of 6 months. Moreover, the scope of the resolution mechanism was extended from transfer pricing/permament establishment issues, to all tax disputes related to double taxation, i.e. all situations when two or more countries claim the right to tax the same income or profits of a company or person. specialists were involved in practical cases on double taxation issues and would be pleased to share this experience with you, if need arises.

For further details, please refer to the European Commission’s press release.

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