Canada, UK Agree On Application Of DTA Arbitration Provisions

Canada and the UK have reached a deal on the application of the arbitration provisions of their double tax agreement (DTA).

The Canadian Government announced on November 26 that the agreement was concluded through an exchange of notes in July and August. It governs the decision-making process of the arbitration board, the precedential value of decisions made by the board, and the type of issues that can be considered. It also sets rules for communication to and by the board, confidentiality procedures, time periods, and fees.

Canada and the UK will notify each other once they have completed the domestic procedures necessary for the agreement’s entry into force. It will enter into force and have effect on the date of the later of these notifications.