Dispute resolution


  • Tax treaties: OECD releases latest MAP statistics

    Mutual agreement procedure (MAP) statistics are now available for the 2014 reporting period.

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  • Base Erosion and Profit Shifting (BEPS)

    The BEPS Action Plan identifies 15 specific actions to address gaps and mismatches in the existing international tax standards, including the development of solutions that prevent countries from resolving treaty-related disputes through the MAP.

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    The online Manual on Effective Mutual Agreement Procedures (MEMAP) sets out basic information and best practices regarding the Mutual Agreement Procedures process.

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In a globalised ecomomy, international double taxation may result where two countries seek to tax the same transactions or activities. Whilst tax treaties directly resolve most such cases, international double taxation may remain where two countries disagree on the interpretation or application of a treaty provision. The mutual agreement procedure (MAP) article of a tax treaty accordingly provides a mechanism to resolve these cross-border tax disputes.

The OECD contributes to the improvement of the mutual agreement procedure through its collection of MAP statistics, a Manual on Effective Mutual Agreement Procedures (MEMAP) and the publication of MAP “Country Profiles”.