The OECD has released six peer review reports on implementation by Belgium, Canada, the Netherlands, Switzerland, the UK and the US of new minimum standards for tax dispute resolution mechanisms under BEPS Action 14.
The six reports include over 110 recommendations relating to the minimum standard. The main areas where improvements are necessary concern:
resolving cases under the mutual agreement procedure (MAP) within the targeted average of 24 months, especially where transfer pricing is involved;
improvements to MAP guidance in some jurisdictions; and
alignment of tax treaty MAP provisions with the Action 14 minimum standard, where not already realised via the ‘Multilateral convention to implement tax treaty related measures to prevent BEPS’.
The OECD has released six peer review reports on implementation by Belgium, Canada, the Netherlands, Switzerland, the UK and the US of new minimum standards for tax dispute resolution mechanisms under BEPS Action 14.
The six reports include over 110 recommendations relating to the minimum standard. The main areas where improvements are necessary concern:
resolving cases under the mutual agreement procedure (MAP) within the targeted average of 24 months, especially where transfer pricing is involved;
improvements to MAP guidance in some jurisdictions; and
alignment of tax treaty MAP provisions with the Action 14 minimum standard, where not already realised via the ‘Multilateral convention to implement tax treaty related measures to prevent BEPS’.
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