EU Joint Transfer Pricing Forum recommends changes to arbitration convention

The EU Joint Transfer Pricing Forum (JTPF) has proposed modifications to the EU Arbitration Convention and revised Code of Conduct to better accommodate transfer pricing disputes.

In a report released on its website, the JTPF recommends that taxpayers be permitted to use the Arbitration Convention in cases where there is the absence of tax payment or where the status of the taxpayer changes, such as from a merger or restructuring.

The report also recommends greater transparency when a country denies access to the Convention and suggests that governments adopt rules regarding tax collection during a cross-border dispute that mirror those applicable to domestic disputes.

The JTPF is a group of tax experts appointed by the European Commission comprised of EU Member State tax administrators and non-government stakeholders.

See:

• Report on Improving the Functioning of the Arbitration Convention  including a revised Code of Conduct for the effective implementation of the Arbitration Convention