Making Dispute Resolution More Effective – MAP Peer Review Report, Thailand (Stage
Inclusive Framework on BEPS: Action 14
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 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 2 peer monitoring of the implementation of
the BEPS Action 14 Minimum Standard by Thailand.
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.