Recurring resistance to tax treaty arbitration as a dispute resolution mechanism

[Extract] The rise of globalisation has not only resulted in an unprecedented increase in cross-border trade, but also in the parallel escalation of disputes in the international tax arena. Disputes usually arise where two different jurisdictions claim the right to tax the same transactions or income, imposing an excessive tax burden on taxpayers. The imposition of double taxation constitutes a significant barrier to the free flow of trade and investment. Where such double taxation disputes remain unresolved, confidence in the certainty, fairness and integrity of the international tax system is undermined.