Arbitration has transformed the resolution of cross-border tax disputes – yet in the United Kingdom, it remains absent from the domestic tax arena. With nearly 50,000 tax appeals overloading the tribunal system, the case for binding domestic tax arbitration is no longer theoretical. Drawing on Portugal’s Centro de Arbitragem Administrativa (CAAD), OECD standards, and the UK’s own treaty-based arbitration commitments, this article maps the constitutional, institutional, and procedural architecture required to make domestic tax arbitration viable within the UK’s legal framework. It advances more than a normative proposition – it demonstrates, through comparative institutional analysis, how arbitral expertise, procedural independence, and principled framework design can resolve systemic failures that adversarial litigation is structurally incapable of addressing.
Arbitration: The International Journal of Arbitration, Mediation and Dispute Management