Is the Interaction between Chapter X of the OECD Transfer Pricing Guidelines and the EU Directive on Tax Dispute Resolution Mechanisms an Effective One?

Abstract

International tax law has been developing rapidly for years. In this article, the author tests the consequences of the new chapter X of the OECD Transfer Pricing Guidelines against the EU Arbitration Directive and the Dutch Tax Arbitration Act. He concludes that, because the Directive does not cover differences in qualification, various situations will fall between two stools.