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OECD: Peer review of dispute resolution (MAP); BEPS Action 14

OECD: Peer review of dispute resolution (MAP)

The Organisation for Economic Cooperation and Development (OECD) today issued a request for comments and input on a peer review of the tax treaty dispute resolution process under Action 14 of the base erosion and profit shifting (BEPS) project.


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As explained by today’s OECD release, the mutual agreement procedure (MAP) peer review and monitoring process under Action 14 of the BEPS project was launched in December 2016, with the peer review process “now well underway.” The peer review process is conducted in two stages. 

  • Under Stage 1, implementation of the Action 14 minimum standard is evaluated for Inclusive Framework members.
  • Stage 2 focuses on monitoring the follow-up of the recommendations resulting from jurisdictions' Stage 1 report. 

To date, four rounds of Stage 1 peer review reports covering 29 jurisdictions have been released. The OECD is now gathering input for the Stage 1 peer reviews of Brazil, Bulgaria, China, Hong Kong, Indonesia, Papua New Guinea, the Russian Federation, and Saudi Arabia. 

The OECD today requested that taxpayers submit input on specific issues relating to access to MAP; clarity and availability of MAP guidance; and the timely implementation of MAP agreements for each of these jurisdictions. Comments are due by 13 December 2018.

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