Under Action 14, countries 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 Action 14 Minimum Standard has been translated into specific terms of
reference and a methodology for the peer review and monitoring process. The minimum
standard is complemented by a set of best practices.The peer review process is conducted
in two stages. Stage 1 assesses countries against the terms of reference of the minimum
standard according to an agreed schedule of review. Stage 2 focuses on monitoring
the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review
report. This report reflects the outcome of the stage 1 peer review of the implementation
of the Action 14 Minimum Standard by Mexico.
Action 14 develops solutions to address obstacles that prevent countries from solving treaty-related disputes under MAP, via a minimum standard in this area as well as a number of best practices. It also includes arbitration as an option for willing countries.