Labyrinth of Choices in Respect of International Tax Dispute Resolution from a Netherlands Perspective

Abstract

In this article, the authors discuss the various options available for resolving international tax disputes from a Netherlands perspective. In particular, the article (i) describes the temporal, territorial and substantive scope of international proceedings; (ii) addresses the concurrence of multiple dispute resolution mechanisms; (iii) considers the legal position of the taxpayer; (iv) sets out possible outcomes; (v) describes possibilities to challenge a final decision; and comments on dispute resolution mechanisms in the context of the OECD Pillar One and Pillar Two proposals.