Brad Rolph of Charles River Associates in Canada takes a closer look at the memorandum of understanding (MOU) on arbitration between the US and Canada and the accompanying arbitration board operating guidelines. He also examines whether the arbitration procedure is accomplishing its objectives to reduce the amount of time it takes to resolve double taxation cases and increase the use of principle-based negotiating positions.
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While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors
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