The competent authority mutual agreement on the implementation of part VI of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting as concluded between the Competent Authority of the Kingdom of Belgium and the Competent Authority of the Kingdom of the Netherlands was published in the Dutch State Gazette of April 17, 2025.
The agreement was signed by the Competent Authority of the Kingdom of the Netherlands on February 20, 2025 and by the Competent Authority of the Kingdom of Belgium on March 10, 2025.
The following subjects are a addresses in the agreement:
- Request for submission of case to arbitration;
- Minimum information necessary to undertake substantive consideration of the case;
- Appointment of arbitrators;
- Arbitration process;
- Communication of information and confidentiality;
- Operating procedures;
- Costs;
- Failure to communicate the decision within the required period;
- Final Decision;
- Implementing the arbitration decision; and
- Entry into effect of Part VI of the Convention.
The full text of the competent authority mutual agreement on the implementation of part VI of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting as concluded between the Competent Authority of the Kingdom of Belgium and the Competent Authority of the Kingdom of the Netherlands as published in the Dutch State Gazette of April 17, 2025 can be found here.
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