Arbitration process: panel selects a party's monetary resolution without reasons, unless parties opt for reasoned decisions.

The default arbitration procedure requires each competent authority to submit proposed resolutions limited to specific monetary dispositions or specified tax rates, may submit supporting papers and replies, and permits the arbitration panel to select one submitted resolution per issue by simple majority without providing a rationale; the decision has no precedential value. Alternatively, where Parties reserve the default, a documentary procedure applies in which panels decide under the Covered Tax Agreement (and, subject to it, domestic law), consider mutually agreed sources, and must provide written reasons citing the legal sources relied upon.

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