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Resolving tax controversies across the EU
Directive 2017/1852 lays down innovative resolution mechanisms with the goal of tackling international double taxation issues between EU member states. The brand-new procedures are aimed at overcoming the critical issues that have arisen so far from the application of the mutual agreement procedures (MAPs) for the resolution of international disputes grounded on double tax treaties and/or the EU Arbitration Convention (90/436/EEC).
Under the new framework, the competent authorities are required to reach an agreement to solve the question in dispute through an ad-hoc ‘arbitration phase’ in case, during the MAP started by the affected person under Directive 2017/1852, the tax authorities do not find a consensus within two years on how to settle the tax controversy.