On 15 April 2024, UK HMRC published a Memorandum of Understanding (MOU) signed with the Isle of Man that establishes the mode of application of the arbitration process provided for in Article 25 of the 2018 income and capital tax agreement between the two jurisdictions. Article 25 (Mutual Agreement Procedure) includes the provision that if any issues of a case cannot be resolved under MAP within two years from being presented to the competent authority of the other Territory, the person that presented the case may request that the case be submitted to arbitration. Unresolved issues may not, however, be...