UK and Canada agree to details of arbitration clause in tax treaty, text available

Canada and the UK have signed an agreement specifying the procedures for arbitration of tax disputes between the two nations, Canada’s Department of Finance announced November 26.

The agreement addresses the selection of the members of the arbitration board, communication with the board, confidentially, timing, and fees.

The agreement will enter into force after the countries have notified each other that the necessary domestic procedures to bring the agreement into force been completed.

Canada and the UK agreed in a 2014 protocol to their 1978 tax treaty to mandatory arbitration if the competent authorities are unable to reach an agreement to resolve a case within three years.

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