International Tax Dispute Resolution in Light of Pillar One: New Challenges and Opportunities

Journal
Malamis, S.E.; Cai, Q.
International; OECD
Bulletin for International Taxation 2021 (Volume 75), No. 2
FormatPDF
USD
45

The “Blueprint on Pillar One” relies on effective and binding dispute prevention and/or resolution mechanisms. Key aspects of these mechanisms pose significant challenges to the traditional system of international tax dispute resolution (ITDR). Nevertheless, Pillar One also represents an opportunity to enhance the traditional ITDR regime.