Mr. Philip Kermode:

Yes. Interestingly, in Article 25 of the OECD model tax convention, there is a process recommended for arbitration. Mr. Lynch also referred to mutual agreement procedures. In practice, however, there is little take-up in the Union of formal arbitration procedures, particularly those involving third parties. The Deputy can understand that some jurisdictions are reluctant to allow third parties to decide on the allocation of revenue in such situations. There must be some solution to this problem.