On 2 October 2017, the Council of the European Union published a draft Council Directive on Tax Dispute Resolution Mechanisms in the European Union. The draft directive is meant to ensure effective resolution of disputes concerning the interpretation and application of such bilateral tax treaties and the Union Arbitration Convention, and in particular, disputes leading to double taxation. The directive provides that complaints should be submitted within three years from the receipt of the first notification of the action resulting in, or that will result in, the question in dispute. Complaints accepted by the competent authorities of the Member States...