Abstract
International tax law has been developing rapidly for years. In this article, the author tests the consequences of the new chapter X of the OECD Transfer Pricing Guidelines against the EU Arbitration Directive and the Dutch Tax Arbitration Act. He concludes that, because the Directive does not cover differences in qualification, various situations will fall between two stools.
Original language | English |
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Article number | 22 |
Pages (from-to) | 35-44 |
Number of pages | 10 |
Journal | International Transfer Pricing Journal |
Volume | 29 |
Issue number | 1 |
Publication status | Published - 1 Jan 2022 |