Question to the HM Treasury:

To ask the Chancellor of the Exchequer, how many large business tax disputes have been submitted to international arbitration in the last 5 years.

The number of such disputes is fewer than five. HMRC are unable to disclosure the exact number as it could risk the identification of individual taxpayer(s).

Arbitration operates as a valuable mechanism under double taxation treaties, to ensure there is route to resolve double taxation where agreement cannot be reached between the relevant tax authorities, providing certainty and finality for taxpayers.

Often resolution can be reached outside of arbitration, which is why the number of arbitration cases are low. For context, for the latest year we have statistics, across 1 January 2023 to 31 December 2023, 348 cases were wholly dealt with under the procedure governing mutual agreement between tax authorities.