On 10 October 2017, the Council of the European Union adopted the Directive on Tax Dispute Resolution Mechanisms in the European Union (‘the Directive’). The Directive expands on an existing framework introduced by the Union Arbitration Convention to create a time-framed, mandatory dispute resolution procedure covering a wider range of disputes. The changes provide for a more expansive guarantee of taxpayers’ rights through greater access to an effective dispute resolution mechanism with an enforceable final outcome.