27. Finally, an update of the 2005 questionnaire on ongoing arbitration proceedings under the EU Arbitration Convention, supplemented by the tax administrations of the Member States, revealed that none of the 24 cases for which the taxpayer had submitted the application before 1 January 2000 had been referred to an arbitration committee. Bilateral and multilateral AAAs are generally bilateral or multilateral, i.e. they also include agreements between the taxable person and one or more foreign tax administrations under the supervision of the cartel procedure (POPs) established in income tax treaties.  The taxable person benefits from such agreements, as it is certain that the income related to the covered transactions is not subject to double taxation by the IRS and the competent foreign tax authorities. In view of these recent transfer pricing successes in the EU and the need to monitor the implementation of the new instruments, but also to continue examining several issues, the Commission has decided to extend the JTPF for a further two-year term. 84. Where appropriate, competent authorities are not obliged to exchange position papers if this makes the APA process more efficient and faster. However, in most cases, it will help ensure that all ACs prepare position papers prior to the start of full negotiations in order to quickly and effectively identify disputes and thus resolve conflicts. Where a certification body has prepared a position paper, any other certification body participating in the negotiations should at least indicate the differences of opinion. All agreements should describe in detail the terms of the JPA. .
Share on Facebook Tweet (Share on Twitter) Share on Linkedin Share on Google+ Pin it (Share on Pinterest)