Making Dispute Resolution More Effective – MAP Full Peer Reviews for Austria, Germany, Ireland, Luxembourg, Malta and the United States (Cycle 1)

Effective tax treaty dispute resolution is essential to providing greater tax certainty and supporting a stable international tax environment. Under BEPS Action 14, Members of the OECD/G20 Inclusive Framework on BEPS committed to implementing a minimum standard to improve the effectiveness and efficiency of the Mutual Agreement Procedure (MAP), which enables jurisdictions to resolve disputes arising from the interpretation and application of tax treaties. This report presents the findings of Cycle 1 of the full peer reviews of Austria, Germany, Ireland, Luxembourg, Malta and the United States. It assesses the implementation of the BEPS Action 14 minimum standard, examining how these jurisdictions prevent and resolve tax treaty disputes, ensure access to MAP and implement MAP agreements. The report identifies progress made, areas for improvement and recommendations to strengthen tax dispute resolution practices.