Abstrakt
Tax treaty arbitration is a topic that has become more important than ever before. In a post-BEPS world, where tax treaty disputes are expected to increase significantly as a result of the different measures taken to address treaty abuse, a well-functioning dispute resolution mechanism is key to solving tax treaty disputes.
Both the OECD and the European Union took initiatives to improve the mechanisms for dispute resolution in tax matters. The OECD amended article 25 of the OECD Model on the mutual agreement procedure and the European Union adopted Council Directive 2017/1852 on tax dispute resolution mechanisms in the European Union.
The aim of this book is to provide tax authorities, policymakers, courts and practitioners an overview of the effectiveness of tax treaty arbitration and the approach towards the recent changes in 36 countries. Chapter 11 represents the Czech national report.