The current mutual agreement procedures cannot satisfactorily solve all tax disputes arising in the application of double tax conventions. To improve the legal protection of the taxpayer in connection with international tax law, some countries have already added arbitration clauses to newly negotiated tax treaties. Within the EU, the Arbitration Convention protects taxpayers in transfer pricing disputes, and the ECJ is called upon to decide tax treaty conflicts under recent tax treaties. The ICC proposed a model arbitration provision. This book provides an in-depth analysis of several concluded and proposed dispute resolution methods.

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• Chapter 1: The lack of legal protection in international tax law
• Chapter 2: Optional arbitration
• Chapter 3: Compulsory arbitration
• Chapter 4: International Courts
• Chapter 5: Preliminary Rulings
• Chapter 6: Summary and Conclusion

Dr Mario Züger works in the Tax Department of Freshfields Bruckhaus Deringer. He received the Mitchell B. Carroll Prize 2001 of the IFA and the Austrian Wolf Theiss Award 2002 for his dissertation.

The mission of the International Bureau of Fiscal Documentation is: “[T]o maintain a knowledge centre providing information about and explanations of international taxation and promoting the study of taxation in general” (Art. 2 of the articles of association). True to this mission, and aware that access to doctoral theses is often limited, IBFD has taken the initiative to make available to a wider public a series of books based on doctoral research, meeting the highest academic standards.

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