Final Report on Improving the Resolution of Tax Treaty Disputes

On 8 December 2006, the OECD released a report entitled "Improving the Resolution of Tax Treaty Disputes". The report includes in the first place a proposal to add to Art. 25 of the  OECD Model Tax Convention an arbitration process to deal with unresolved issues that prevent competent authorities from reaching a mutual agreement. In addition, the report includes a revised version to the Commentary on Art. 25 ultimately designed to enhance the effectiveness of the mutual agr…