Arbitration in International Tax Matters: Bilateral Convention Article

In order to assist in the implementation of arbitration in tax matters in conformity with the guidelines established in the ICC Policy Statement, the Commission has prepared a model article, which could be adopted in bilateral taxation conventions.

This draft Article is designed having regard to the OECD Model Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital (the "OECD Model"). It could, with appropriate modifications, be adopted in bilateral tax conventions based on other models.