On 12 January 2024, the competent authorities of the Republic of Singapore and the Kingdom of the Netherlands signed a competent authority arrangement (“CAA”) to establish the mode of application of the arbitration proceedings provided for in Part VI (Arbitration) of the MLI.
The arbitration provisions allow taxpayers to request for issues arising from a Mutual Agreement Procedure case which remained unresolved after a two-year time period to be submitted to an arbitration panel for resolution.
The full text of the CAA is published as Annex B to the Singapore-Netherlands DTA which is available on the Inland Revenue Authority of Singapore’s website here.