Introduction

On 30 January 2007, OECD countries have agreed to include an arbitration provision in article 25 paragraph 5 of the 2008 OECD Model Tax Convention on Income and Capital . The OECD Model serves and has served as a basis for the majority of bilateral tax treaties. It can therefore be expected that the newly published amendment will strongly favour the inclusion of arbitration clauses in future bilateral tax treaties and promote the revision of existing treaties. The proposed arbitration provision would oblige the tax administrations of the treaty states to enter into an ...