Mutual Attribution Agreement

The agreed notification framework now distinguishes between “attribution cases” and “other cases.” An arbitration agreement is a written contract in which two or more parties agree to settle a dispute outside the court. The arbitration agreement is generally a clause in a broader contract. The dispute may include, among other things, the performance of a particular contract, a right to unfair or illegal treatment in the workplace, a defective product, including the performance of a particular contract, and a defective product. People are free to use arbitration on anything they might otherwise solve through court proceedings. If you need help developing an arbitration agreement or understanding, you should contact an arbitration lawyer for help. Historically, domestic tax remedies have been seen as the first approach to resolving international tax or transfer pricing disputes. Taxpayers have often initiated mutual agreement (POP) procedures to resolve a dispute and ensure security. The POP essentially offered a dispute resolution mechanism between the public authorities (amicable procedure), with the competent authorities striving to settle disputes relating to tax contracts on a consensual basis. Some might argue that arbitration has the advantage of encouraging Member States to settle disputes before the two-year deadline expires, which would be a success rather than a failure of the convention. However, statistics also show that 202 cases had exceeded the two-year deadline, while it had been cancelled with the taxpayer`s consent. This indicates that taxpayers do not always view the arbitration available to them under the agreement as a desirable means of resolving double taxation. Overall, it is clear that the MLI extends taxpayers` access to three years, both in terms of extending the period during which taxpayers must initiate a POB period, provides an effective two-year period for the relevant authorities to resolve a case (after that date, it may be subject to arbitration).

The MLI has led to a greater homogeneity of approach on key issues such as arbitration and, above all, the adoption of a single map article for covered tax treaties.