This article analyses some of the features of the arbitration provisions included in the tax treaties concluded by the US. The purpose of the article is to analyse these arbitration provisions in the light of the recommendations of the OECD and the UN Model Tax Conventions. The differences emphasized between the arbitration provisions included in the tax treaties concluded by the US and Article 25(5) of the Model Tax Conventions may be of interest to countries considering different options for designing arbitration provisions in their tax treaties.
Intertax