Adoption of the EU Council Directive on Tax Dispute Resolution Mechanisms in the European Union on 10 October 2016 is a milestone in international tax dispute resolution. The Directive offers a uniform mechanism to address tax treaty disputes among EU member states that meets the BEPS Action 14 minimum standard, and largely renders the arbitration…

On 12 September 2017, the CJEU confirmed that it has jurisdiction over a dispute between Austria and Germany regarding the interpretation of a double tax convention entered into between the two Member States under article 273 TFEU.1)CJEU 12 September 2017, case number C-648/15, Opinion delivered by Advocate-General Mengozzi on 27 April 2017. The case was…