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Tax dispute resolution: Switzerland

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HMRC has published the Switzerland-UK memorandum of understanding (MOU) on arbitration under Article 24 of the UK-Switzerland Double Tax Convention. Article 24 deals with the mutual agreement procedure for dealing with disagreements on the application of the Convention. Paragraph 5 of that Article enables unresolved issues to be resolved by arbitration.

The MOU, which was signed on 16 June 2021, includes detail on the process for making an arbitration request, the three-year time limits, the selection and appointment of arbitrators, costs, legal principles, and implementation of any final arbitration decision.

Issue: 1548
Categories: News