Presents a detailed view into the possibilities and impossibilities of the application of the EC Arbitration Convention. The Convention was already adopted (but not yet effective) in 1990 and the first effective five-year period ran until 31 December 1999. At the end of 2003, the EU Joint Transfer Pricing Forum adopted a proposal for a Code of Conduct for the effective implementation of the EC Arbitration Convention. This proposal was taken up by the European Commission and on 7 December 2004 the ECOFIN Council adopted it. The author gives a description of what will be changed, an analysis of the issues which have not been solved, and finally deals with the implementation problems regarding the re-entry into force of the EC Arbitration Convention.