As from June 2019, new EU rules come into force to ensure that businesses and citizens can resolve disputes related to the interpretation of tax treaties more swiftly and effectively between the Member States, making daily life easier and offering much more tax certainty for businesses and individuals experiencing double taxation issues.
The new rules will 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.
Estimates show that there are currently around 2000 disputes pending in the EU, out of which around 900 are over 2 years old and estimated to be worth €10.5 billion.
As such, taxpayers will have much more certainty when it comes to seeking resolution to their interpretation of tax treaties or double taxation problems. In particular, a wider range of cases will be covered and the EU Member States will now have clear deadlines to agree on a binding solution, giving citizens and companies more timely decisions.
The new rules that applied can help member states to have a legal duty to take conclusive decisions of these problems:
Source: European Commission
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