Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607

Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 20

Nature of specific case mutual agreement procedure under OECD Model (p. 609)

Once the taxpayer has filed an application for a specific case MAP...

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Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 19

Only cases where taxes have been charged are covered (p. 611)

Under the wording of article 19(l)(a) of the MLI, only cases where taxes have...

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Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 28 - Article 28(2)

Arbitration reservations are subject to other CTA party’s acceptance (p. 611)

Article 28(2)(a) permits the parties to the MLI to formulate one...

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