Council Directive (EU) 2017/1852 (tax dispute resolution): sourced answers
3 answers to specific questions — each with a verbatim quote from an official source and a link to it.
Every answer is checked against a verbatim quote from a stored copy of its source and has passed an independent review. This is reference information, not legal advice: rules change, and the outcome depends on your circumstances.
Tax treaty or act
Within what period can a mutual agreement procedure request be filed
3 years from the first notification, simultaneously to every affected authority
«within 3 years from the receipt of the first notification of the action resulting in, or that will result in, the question in dispute, regardless of whether the affected person has recourse to the remedies available under the national law of any of the Member States concerned. The affected person shall simultaneously submit the complaint with the same information to each competent authority, and shall indicate in the complaint which other Member States are concerned. The affected person shall ensure that each Member State concerned receives the complaint in at least one of the following languages: (a) one of that Member State's official languages in accordance with national law; or (b) any other language that such a Member State accepts for this purpose. 2. Each competent authority shall acknowledge receipt of the complaint within 2 months from the receipt of the complaint. Each competent authority shall also inform the competent authorities of the other Member States concerned of the receipt of the complaint within 2 months of such receipt. …»
Source: eur-lex.europa.eu · source copy as of 2026-10-03
3 years from first notification
«within 3 years from the receipt of the first notification of the action resulting in, or that will result in, the question in dispute, regardless of whether the affected person has recourse to the remedies available under the national law of any of the Member States concerned. The affected person shall simultaneously submit the complaint with the same information to each competent authority, and shall indicate in the complaint which other Member States are concerned. The affected person shall ensure that each Member State concerned receives the complaint in at least one of the following languages: (a) one of that Member State's official languages in accordance with national law; or (b) any other language that such a Member State accepts for this purpose. 2. Each competent authority shall acknowledge receipt of the complaint within 2 months from the receipt of the complaint. Each competent authority shall also inform the competent authorities of the other Member States concerned of the receipt of the complaint within 2 months of such receipt. …»
Source: eur-lex.europa.eu · source copy as of 2026-10-03
From what date do the provisions of the agreement or act apply
The directive applies to complaints submitted from 1 July 2019 onwards, concerning income or capital for tax years beginning on or after 1 January 2018 (Article 23).
«Article 23 Entry into force This Directive shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply to any complaint submitted from 1 July 2019 onwards relating to questions of dispute relating to income or capital earned in a tax year commencing on or after 1 January 2018. Competent authorities of Member States concerned may however agree to apply this Directive with regard to any complaint that was submitted prior to that day or to earlier tax years. Article 24 Addressees This Directive is addressed to the Member States. Done at Luxembourg, 10 October 2017. For the Council The President T. TÕNISTE»
Source: eur-lex.europa.eu · source copy as of 2026-10-03
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