Arbitration compatibility limits arbitration submissions when prior mandatory arbitration exists and allows reservations for covered tax agreements. Where Parties elect to apply this Part, its arbitration provisions replace arbitration clauses in Covered Tax Agreements between two Contracting Jurisdictions that have both notified the Depositary; notifying Parties must state whether each Covered Tax Agreement contains such a provision and cite its article and paragraph. Issues already subject to a previously established arbitration panel under a bilateral or multilateral convention providing mandatory binding arbitration are excluded from submission under this Part, and Parties may reserve this Part's non application for identified Covered Tax Agreements that already provide for mandatory binding arbitration.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Arbitration compatibility limits arbitration submissions when prior mandatory arbitration exists and allows reservations for covered tax agreements.
Where Parties elect to apply this Part, its arbitration provisions replace arbitration clauses in Covered Tax Agreements between two Contracting Jurisdictions that have both notified the Depositary; notifying Parties must state whether each Covered Tax Agreement contains such a provision and cite its article and paragraph. Issues already subject to a previously established arbitration panel under a bilateral or multilateral convention providing mandatory binding arbitration are excluded from submission under this Part, and Parties may reserve this Part's non application for identified Covered Tax Agreements that already provide for mandatory binding arbitration.
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