On 5th of October 2015, the Organization for Economic Co-operation and Development (OECD) released a report called “Making Dispute Resolution Mechanisms More Effective”, which suggests measures for international tax dispute resolution. The report discusses a framework of the mutual agreement procedure (MAP) that can help managing disputes stemming from international double taxation agreements. MAP is applied if two countries have difficulties in agreeing on common interpretation and application of double taxation treaty provision.
In order to solve cross-border tax disputes more efficiently, the OECD report recommends to the member countries:
- To agree on minimum standards regarding treaty-related disputes;
- To put efforts to resolve disputes in a timeframe of 24 months;
- To use the services of one of 20 countries providing mandatory binding arbitration, e.g., U.S., France, Germany, UK, and Australia.
The aforementioned OECD measures aim at effective and consistent implementation of double taxation treaties as well as effective and timely dispute resolution.