Legislating the Double Taxation Dispute Resolution (EU) Regulations 2020
This Tax Information and Impact Note is about legislation resolving tax disputes arising from the interpretation and application of tax treaties between the UK and Member States
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This measure builds on the United Kingdom’s network of bilateral tax treaties with other Member States and on the existing Convention on the elimination of double taxation in connection with the adjustment of associated enterprise.
This provides a mechanism specifically for Member States to resolve disputes where double taxation occurs as a result of an upward adjustment of profits by one Member State in respect of a connected party transaction where the other enterprise is tax resident in another Member State.