Given the complexity of income tax laws, disputes concerning the interpretation and application of these laws are probably unavoidable in systems based on the rule of law. A main preoccupation of those responsible for designing tax systems is therefore the need to adopt measures that minimize such disputes and, where this is not possible, that ensure that disputes are resolved fairly and effectively. This is particularly important for policy makers and tax administrations of developing countries because the fair and effective resolution of tax disputes serves to balance the need to raise revenues and the need to attract and keep foreign investment. Achieving the right balance contributes
to the strengthening of domestic resource mobilization.