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Mandatory Tax Treaty Arbitration

The United States has entered into new treaties and protocols with Belgium, Canada, Germany, and France to allow for a mandatory arbitration process to supplement the historic negotiation process used in the Mutual Agreement Procedure.

Mandatory Arbitration Documents with Germany, Belgium, Canada, and France

Taxpayer Agreements for MAP Arbitration

Identification of Arbitrators

The Internal Revenue Service (IRS) has entered into an agreement with the International Centre for Dispute Resolution (ICDR) to provide administrative services in support of arbitration under the Mutual Agreement Procedure (MAP) article of United States income tax treaties. The ICDR carries out the international operations of the American Arbitration Association (AAA), a not-for-profit public service organization. The ICDR’s headquarters are in New York City, and it is supported by a network of cooperative agreements with institutions and key alliances covering over 40 countries.  

The administrative services provided by the ICDR will include training and selection of arbitrators along with case management for cases sent to arbitration.  In providing these services, ICDR draws on its institutional experience, international expertise, multilingual case management staff, flexibility and a commitment to service along with cultural sensitivity.

Persons interested in serving as arbitrators must have significant international tax experience, preferably with extensive involvement in the development and resolution of transfer pricing matters.  Persons interested in serving as arbitrators for unagreed MAP cases should contact Luis Martinez, Vice President of ICDR, at


Page Last Reviewed or Updated: 24-Oct-2016