Competent authority mutual agreement on the implementation of Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, Ministerie van FinanciënMutual Agreement on Arbitration Process • October 24th, 2022
Contract Type FiledOctober 24th, 2022The competent authorities of the Netherlands and of Luxembourg (hereinafter referred to as the ‘Contracting Jurisdictions’) hereby enter into the following mutual agreement (hereinafter referred to as the ‘Agreement’) to establish the mode of application of the arbitration process provided for in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (hereinafter referred to as ‘the Convention’). This Agreement is entered into pursuant to Article 25 of the Convention between the Kingdom of the Netherlands and the Grand Duchy of Luxembourg for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital (hereinafter referred to as ‘the Covered Tax Agreement’), as modified by Article 16 of the Convention, and paragraph 10 of Article 19 of the Convention. The competent authorities may modify or supplement this Agreement by an exchange of letters between them.