Tax Notes Quotes Victor Jaramillo on Alternative Dispute Resolution for Pillar 2

The OECD pillar 2 project contains substantive minimum tax rules but provides no dispute resolution tools, and other mechanisms are not directly applicable, taxpayer representatives warned April 10 at a Europe-U.S. tax conference in Amsterdam.

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Bilateral investment treaties usually have a carveout for taxes. The United States has signed 47 bilateral investment treaties, with 39 treaties in force, noted Victor A. Jaramillo of Caplin & Drysdale’s Washington office. Of those treaties, only 11 also apply to taxation, but those jurisdictions — for example, Kyrgyzstan, Armenia, and Argentina — do not belong to the largest world economies, he said.

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