International tax dispute resolution: Breaking the impasse

February 01 2016

Peter Nias, international tax specialist barrister at Pump Court Tax Chambers in London, analyses trends in international tax dispute resolution, looking at alternative dispute resolution methods and whether the OECD’s recent work in this area represents a missed opportunity.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Transfer Pricing

IKEA announces intention to dispute A$171m ATO tax claim

The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes

Sam Sholli, January 07 2026

Indirect Tax

This month in indirect tax: UK supermarket loses VAT court battle

Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs

Sam Sholli, January 07 2026

Direct Tax

Landmark pillar two side-by-side agreement reached

The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two

Tom Baker, January 05 2026

Awards

ITR World Tax 2026 website - 1200x627.png

ITR World Tax 2027 and ITR Tax Awards 2026 opens for submissions

ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally

John Harrison, January 05 2026

Direct Tax

EU pillar two directive may violate freedom of establishment: academic

Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued

Sam Sholli, January 05 2026

Direct Tax

Brazilian advisers warn of disputes over crypto transaction tax proposals

Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR

Sam Sholli, December 23 2025

Direct Tax

A taxing week: Trump’s pillar two deal won’t save the project

The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two

Sam Sholli, December 22 2025

Direct Tax

MHA acquires tax and consulting services firm in UAE

The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year

Sam Sholli, December 22 2025

Direct Tax

Editor’s picks: ITR’s top stories of 2025

ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial

Tom Baker, December 22 2025

Direct Tax

This week in tax: EU nations drop US pillar two carve-out objections

The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team

Sam Sholli, December 19 2025