Dispute resolution


  • BEPS Action 14 Peer Review and Monitoring

    In October 2016, the OECD released key documents, approved by the Inclusive Framework on BEPS, that will form the basis of the MAP peer review and monitoring process under Action 14 of the BEPS Action Plan. The peer review and monitoring process will be conducted by the Forum on Tax Administration MAP Forum in accordance with the Terms of Reference and Assessment Methodology, with all members participating on an equal footing.

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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 profiles.