Dispute resolution


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”.