Based on Article 23, of COUNCIL DIRECTIVE (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union the provisions laid down in said Directive apply to any complaint submitted from 1 July 2019 onwards relating to questions of dispute relating to income or capital earned in a tax year commencing on or after 1 January 2018.
The purpose of the new rules is to ensure that businesses and citizens can resolve disputes related to the interpretation of tax treaties more swiftly and effectively.
The new rules will also cover issues related to double taxation which occurs when two or more countries claim the right to tax the same income or profits of a company or person. This can happen, for example, due to a mismatch in national rules or different interpretations of a bilateral tax treaty with regards transfer pricing arrangements.
Key differences between the old and the new rules:
Before Council Directive 2017/1852 |
Council Directive 2017/1852 |
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Click here to be forwarded to the text of COUNCIL DIRECTIVE (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union.
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