On 14 October 2017, Council Directive (EU) 2017/1852 of 10 October 2017 was published in the Official Journal of the European Union. The Directive includes rules to ensure effective resolution of disputes concerning the interpretation and application of such bilateral tax treaties and the Union Arbitration Convention, and in particular, disputes leading to double taxation. EU Member States have until 30 June 2019 to bring into force the laws, regulations, and administrative provisions necessary to comply with the Directive. The Directive will apply to any complaint submitted from 1 July 2019 onwards relating to questions of dispute relating to income or capital earned in a tax year commencing on or after 1 January 2018.
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