Singapore-New Zealand Competent Authority Arrangement on the Application of the MLI’s Arbitration Provisions

  • December 13, 2024

Singapore and New Zealand authorities reach agreement on Measures to Prevent Base Erosion and Profit Shifting (“MLI”)

  1. On 18 and 21 November 2024, the competent authorities of Singapore and New Zealand signed a Competent Authority Arrangement (CAA) to establish procedures for initiating and conducting arbitration proceedings under Part VI (Arbitration) of the Multilateral Instrument (MLI).
  2. The arbitration provisions enable taxpayers to submit unresolved issues arising from Mutual Agreement Procedures (MAPs) that have been pending for two years or longer to an arbitration panel for resolution
  3. The full text of the Competent Authority Arrangement (CAA) can be found as Annex B to the Singapore-New Zealand Double Taxation Agreement (DTA) on the Inland Revenue Authority of Singapore’s website

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