id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-376	Farah, Ehab	Mandatory Arbitration of International Tax Disputes: A Solution in Search of a Problem	2022	51	.pdf	application/pdf	21428	999	48	For example, the Dutch representative (Mr. Gerrit Groen) has pointed out that mandatory tax treaty arbitration should require that the competent authorities would be obliged to initiate a mutual agreement procedure at the request of the taxpayer. This is why competent authorities are generally receptive to taxpayers’ requests to grant MAP assistance.86 In the U.S. refusal to grant MAP assistance is also rare.87 During a joint conference of the Canadian and U.S. branches of the International Fiscal Association in Toronto on May 18, 2007 discussing a fifth protocol to the Canada-U.S. income tax treaty, Frank Ng said that: “In general the success rate of competent authority cases handled by the IRS is good, with only about 5% of cases failing to produce tax relief.	cache/ftr-376.pdf	txt/ftr-376.txt