G20/OECD revise their programmes to facilitate dispute resolution between tax administrations
In October, the OECD released key documents that form the basis of the Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan.
Action 14 aims to make the mechanism of resolving disputes between states arising from double taxation treaties more effective. Currently, such disputes may take years. The newly released documents regulate the assessment methodology for the peer review and monitoring process, and the MAP statistics reporting framework. Through peer review, the OECD seeks to point out the (in)effectiveness of dispute resolution in individual states. Within statistics reporting, individual states have to state how many MAP disputes they are solving, how many were closed during the year and how long it took to settle individual cases. This should provide for a higher transparency of MAP processes and motivate individual states to resolve disputes at a greater speed.
The results of the peer review and analyses will be released gradually; the first part is to be published in December 2016, to be followed by comments by taxable entities.