Making Dispute Resolution More Effective – Simplified Peer Review, Seychelles (Stage 1)

Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The initial peer review process was conducted in two stages. Stage 1 assessed countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focused on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. Following the conclusion of the initial peer review process in 2022, a continued monitoring process has started whereby all Inclusive Framework member jurisdictions will be subject to continued monitoring: jurisdictions that have "meaningful MAP experience" would undergo a full peer review process once every four years and those that do not would undergo a two-stage simplified peer review process. This report reflects the outcome of Stage 1 of the simplified peer review of the implementation of the BEPS Action 14 Minimum Standard by Seychelles.