Pinto Nogueira, João Félix; Pistone, Pasquale; Garcia … - 2020
-taxation and encouraged member states to include an appropriate subject-to-tax clause in their double taxation conventions … for binding arbitration with regard to tax "disputes". While the TDRD does not address double taxation outside of a tax … treaty context, it is a huge step towards the removal of double taxation caused by diverging interpretation and application …