Tax Dispute Resolution

This Tax Dossier was last updated on 22 August 2022

Disputes between different Member States on how to interpret or apply the provisions of tax treaties and of the Arbitration Convention (90/436) (in particular disputes leading to double taxation) may harm businesses operating cross-border. The EU Directive on tax dispute resolution mechanisms (2017/1852) aims to provide more comprehensive, effective and sustainable mechanisms for dispute resolution to ensure legal certainty, a business-friendly environment and fairer tax systems in the European Union. This Tax Dossier includes a table continuously updated with the implementation status per Member State and offers quick access to IBFD articles and papers on this subject.

Analysis of the EU Tax Dispute Resolution Directive

Dive into a number of commentaries and analyses of the EU Directive published in IBFD's journal collections between 2017 and 2018.

• The EU Dispute Resolution Directive (2017/1852) and Fair Trial Protection under Article 47 of the EU Charter of Fundamental Rights

Daniele De Carolis

• EU Tax Dispute Resolution Directive (2017/1852): Paving the Path Toward a European Tax Court?

Jasna Voje

• A Collaborative Relationship in the Resolution of International Tax Disputes and Alternative Measures for Dispute Resolution in a Post-BEPS Era

Gracia Mª Luchena Mozo

• Cross-Border Tax Dispute Resolution in the 21st century: A Comparative Study of Existing Bilateral and Multilateral Remedies

Sriram Govind and Laura Turcan

• Opinion Statement FC 4/2017 on the Proposed Directive on Double Taxation Dispute Resolution Mechanisms in the European Union

CFE Fiscal Committee

• The Commission’s Proposal for a Directive on Double Taxation Dispute Resolution Mechanisms: Overcoming the Final Hurdle of Juridical Double Taxation within the European Union?

Luca Cerioni