Canada and UK Agree on Procedures for Arbitration Pro.. | KPMG | CA

Canada and UK Agree on Procedures for Arbitration Provision

Canada and UK Agree on Procedures for Arbitration Pro..

Global Tax Adviser, January 05, 2016. Canada and the UK have signed an agreement that clearly outlines procedures for the application of the arbitration provisions of the Canada-UK tax treaty. This legally binding agreement establishes rules and procedures under paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) of the treaty, and as such covers:


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  • The decision-making process of the arbitration board 
  • The precedential value of decisions rendered by the board 
  • The type of issues that can be considered by the board 
  • Communication to and by the board 
  • Confidentiality 
  • Time periods and fees. 

This agreement, which was publicized by Finance on November 26, 2015, will come into force after the two countries have notified each other that the necessary domestic steps to bring the agreement into force have been completed. The result will be a clearly outlined process for the arbitration of tax disputes between the two nations.

For more information, contact your KPMG adviser. 


Information is current to January 05, 2016. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500

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