The OECD and G20, via the Base-Erosion and Profit Shifting (BEPS) project, have recently taken measures under Action 14 to improve tax dispute resolution mechanisms by promoting the timely resolution of treaty-related disputes via the Mutual Agreement Procedure (MAP). The purpose of this article is to understand how the existing tax dispute resolution mechanism works in the context of the MAP and to evaluate its suitability, effectiveness and efficiency. In this context, this article examines whether the emergence of new legal technology could complement the MAP and supplementary arbitration, and proposes both theoretical and practical solutions aimed at making the tax dispute resolution mechanism more effective by speeding up resolution, attracting both developed and developing countries, as well as coordinating competent authorities.
How to Cite:
Taramountas, K., 2019. The Mutual Agreement Procedure: Coordinating the Global Tax Orchestra. LSE Law Review, 4, pp.39–62.