000			02056nab a2200265 c 4500
999			_c141156 _d141156
003			ES-MaIEF
005			20190924190103.0
007			ta
008			190924s2019 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
041			_aeng
100	1		_962794 _aPit, H. M.
245		4	_aThe changed landscape of Tax Dispute Resolution within the EU _b considerations of the Directive on Tax Dispute Resolution Mechanisms _c H. M. Pit
260			_c2019
500			_aResumen.
520			_aWith the Council's adoption of the Directive on Tax Dispute Resolution Mechanisms on 10 October 2017, the resolution of tax disputes among Member States enters a new phase. What originally started in 1976 with a proposal for a directive to settle transfer pricing disputes by means of arbitration has led to the adoption of a directive in 2017 for all disputes among Member States on the interpretation and application of their mutual tax treaties on income and capital. This Directive aims at improving existing dispute resolution mechanisms contained in these tax treaties and the EU Arbitration Convention. To that end, four specific objectives have been defined in the directive's preamble, which are (1) broadening the scope of application of the EU Arbitration Convention to all disputes concerning the application and interpretation of tax treaties between Member States; (2) ensuring legal certainty for taxpayers; (3) ensuring effectiveness and efficiency; and (4) ensuring transparency. This article examines whether each of these objectives is attained in light of the experiences gained with the EU Arbitration Convention.
650		4	_942375 _aDERECHO TRIBUTARIO
650		4	_944303 _aFISCALIDAD INTERNACIONAL
650		4	_928417 _aARBITRAJE
650		7	_966265 _aRESOLUCIONES EXTRAJUDICIALES DE CONFLICTOS
650		4	_941975 _aDERECHO COMUNITARIO EUROPEO
650		4	_aUNION EUROPEA _948644
773	0		_9161017 _oOP 2141/2019/8/9 _tIntertax _w(IEF)55619 _x 0165-2826 _g v. 47, n. 8/9, August / September 2019, p. 745-756
942			_cART