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Arbitration Agreement between Guernsey and Luxembourg — Orbitax Tax News & Alerts

The Guernsey Government has published a mutual agreement with Luxembourg to establish the mode of application of the arbitration process provided for in paragraph 5 of Article 24 (Mutual Agreement Procedure) of the 2013 tax treaty between the two jurisdictions. As provided by paragraph 5, if the competent authorities are unable to reach an agreement to resolve a case within two years from the presentation of the case, any unresolved issues arising from the case shall be submitted to arbitration if both competent authorities and the taxpayer agree. The mutual agreement was signed on 10 October 2022 and entered into force on the same date.