Even in the event of an arbitration request, the EU review found that there could be many shortcomings in the system, including delays or lack of setting up the advisory committee and the lack of agreement on the appointment of the chairman of the advisory committee that delays or prevents the procedure. Within the EU, the EU Arbitration Convention came into force on 1 January 1995 as an instrument that promised to allow the elimination of double taxation between Member States. It is important that it provides for a binding and binding arbitration mechanism that eliminates double taxation, with the advice of an independent advisory body, if the competent authorities fail to reach an agreement after two years. This went beyond the existing bilateral agreements at the time, which simply required the competent authorities to make their «best efforts» to eliminate double taxation. To put an end to a topical issue, it was interesting to note that not only does the UK and its former partners in eu member states continue to deal with ongoing cases in the EU Advisory Committee, but the UK has also signed the EU directive, and it is not expected to change what Brexit looks like. This is a sure sign that the United Kingdom, like many countries in the international community, takes its commitments seriously when it comes to dispute resolution. In particular, Article 19 of the compulsory arbitration procedure must be mandatory if the competent authorities are unable to reach an agreement on the settlement of a case within two years of their start. This is a significant restriction on POPs cases in the past, as the competent authorities were only required to try to resolve cases and disputes could be resolved indefinitely. Section 19 ensures that treaty disputes will be resolved within a specified time frame, making the MAP a more attractive option for taxpayers. In addition, sections 20 to 25 provide for the practical functioning of arbitration. In the past, it was often practical constraints or a lack of agreement on how to proceed that blocked the solution. The Mutual Agreement Procedure (MAP) (also known as the Competent Authority Procedure (CAP) is an administrative procedure designed to help resolve the resulting difficulties: overall, it is clear that the MLI extends access to the subjects to three years, both with regard to the lengthening of the period during which the subjects must initiate a map period, and provides for an effective two-year period for the competent authorities.

it may be subject to arbitration). The MLI has led to a greater homogeneity of approach on key issues such as arbitration and, above all, the adoption of a single map article for covered tax treaties.