Document Type
Article
Publication Date
2002
ISSN
1088-5625
Publisher
George Mason University School of Law
Language
en-US
Abstract
Notwithstanding similar fiscal objectives, countries that conclude income tax treaties often arrive at radically different results when treaty language is applied to a practical problem. The task of resolving disagreement on treaty interpretation falls either to national courts or to joint efforts by the tax administrations to work out differences on a voluntary basis. Neither alternative is satisfactory. Judicial proceedings lack political neutrality and yield inconsistent results. And the process for "mutual agreement" among competent fiscal authorities is fraught with delays and uncertainty.
Recommended Citation
William W. Park,
Income Tax Treaty Arbitration
,
in
10
George Mason Law Review
803
(2002).
Available at:
https://scholarship.law.bu.edu/faculty_scholarship/2707
Included in
Commercial Law Commons, Dispute Resolution and Arbitration Commons, International Law Commons
Comments
Reprinted in 31 Tax Management International Journal 219 (2002)