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Public Consultation on Improving double taxation dispute resolution mechanisms



Consultation on Improving double taxation dispute resolution mechanisms

Policy field(s)


Target group(s)

The European Commission seeks the views of all interested parties on how the current double taxation dispute resolution mechanisms operate and can be improved.

The current mechanisms (Mutual Agreement Procedure, Arbitration) are provided by the bilateral tax treaties entered into by Member States and, specifically, by the EU multilateral Arbitration Convention (i.e. Convention 90/436/EEC on the elimination of double taxation in connection with the adjustment of profits of associated enterprises). The scope of the Arbitration Convention is limited to transfer pricing and allocation of profits to Permanent Establishment.

Period of consultation

From 16.02.2016 to 10.05.2016

Objective of the consultation

The consultation is part of the work on implementing the June 2015 Action Plan for a Fair and efficient Corporate tax system in the European Union and focuses on improving the double taxation dispute resolution mechanism.

The general objective of the initiative is to create a more attractive investment and business environment and to achieve greater legal certainty at a time where recent significant changes to increase tax transparency and fight against tax fraud and tax evasion may contribute to an exponential increase of disputes.

This consultation aims at gathering all stakeholders' views in particular on:

  • the relevance of removing double taxation for enterprises operating cross border;
  • the impact and effectiveness of the above-mentioned double taxation dispute resolution mechanisms for business and enterprises established in the European Union,
  • how these mechanisms can be improved, and,
  • the solutions which are discussed.


How to submit your contribution

This is an open consultation seeking to capture the views and opinions of any interested persons (citizens, companies, NGOs, academics, local and other public authorities, international organisations, etc.).
If you wish to contribute by answering the open consultation, please click here to submit your contribution.

View the consultation document

Consultation documentpdf(104 kB) Choose translations of the previous link  (only for viewing)

Reference documents and other, related consultations

Action Plan of 17th June 2015pdf Choose translations of the previous link 

Contact details

responsible service

Directorate-General for Taxation and Customs Union
Indirect Taxes other than VAT - Unit TAXUD/D2


postal address

European Commission
Directorate-General for Taxation and Customs Union
Direct Tax Policy & Cooperation - Unit TAXUD/D2
Rue de Spa 3, Office SPA3 06/069
B-1049 Brussels


View the contributions

In the interests of transparency, organisations have been invited to provide the public with relevant information about themselves by registering in the Transparency Register and subscribing to its Code of Conduct. If the organisation is not registered, the submission is published separately from the registered organisations.
- Contributions from Registered Organisations
- Contributions from Public Authorities (e.g. international, European, national, regional)
- Individual Contributions

  • Citizens
  • Unregistered Organisations

Results of consultation and next steps

Protection of personal data

Specific privacy statementpdf(15 kB) Choose translations of the previous link 

Received contributions will be published on the Internet. It is important to read the Specific Privacy Statement attached to this consultation for information on how your personal data and contribution will be dealt with.