Entry into force of system to resolve tax disputes

01/07/2019 (Agence Europe) – The system to resolve tax disputes arising from double taxation of companies from different Member States entered into force on Monday 1^st July. Adopted by the EU Council in October 2017 (see EUROPE 11880/29), the Directive introduces a mutual agreement procedure initiated by a taxpayer complaint, according to which Member States must try to resolve the dispute amicably within two years. If this procedure fails, it will switch to a dispute resolution procedure in which the competent national authorities involved will ultimately take a binding decision. The system normally applies to complaints submitted from 1^stJuly 2019 onwards, relating to questions of dispute in matters of income or capital earned in a tax year commencing on or after 1^st January 2018. According to the Commission's estimates, there are currently 2,000 such disputes pending in the EU. (MF)