联合国税收框架公约第一轮谈判的商业收获3（英）-2025.8_6页_426kb

ICC Summary of Response to UN INC Workstream III Draft Issues Note

The International Chamber of Commerce (ICC) supports the UN's Intergovernmental Negotiating Committee's work on the Early Protocol for the Prevention and Resolution of Tax Disputes, emphasizing the need for a consistent, stable, and certain global tax system to promote trade and investment. The draft issues note correctly identifies challenges such as lengthy and costly tax dispute litigation, particularly in cross-border cases where double taxation risks persist.

Key recommendations include strengthening prevention mechanisms through clear rules, early engagement, and cooperative compliance, which are effective, especially in developing countries. ICC also advocates for enhanced use of Alternative Dispute Resolution (ADR) tools like arbitration and mediation, noting their timeliness, cost-effectiveness, and ability to provide binding outcomes or foster mutual understanding, thereby reducing risks of double taxation and boosting investor confidence.

Taxpayers are highlighted as crucial participants who can clarify facts and business models to prevent and resolve disputes efficiently. Furthermore, clear guidelines are needed on how new tax dispute mechanisms interact with existing ones, such as mutual agreement procedures, to ensure coherence and avoid duplication.

ICC remains committed to the process, stressing the importance of taxpayer input to develop practical solutions. The organization calls for ongoing dialogue, including exploring mechanisms like binding arbitration and advance pricing agreements, to create an efficient, global framework for tax dispute resolution.