On October 20, the OECD released key document that will form the basis of the Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan. The document was approved by the Inclusive Framework on BEPS and OECD will be seeking taxpayer input in the coming weeks.
Action 14 calls for effective dispute resolution mechanisms to resolve tax treaty-related disputes. The BEPS package outlines the minimum standards and best practices for resolving treaty-related disputes under the Mutual Agreement Procedure (MAP).
The document includes Terms of Reference (the minimum standard); the Assessment Methodology for the peer review and monitoring process and the MAP statistics reporting framework which reflects the collaborative approach for competent authorities and Guidance on information and documentation to be submitted with a MAP request.
The documents inform that the peer review will take place on the basis of the existing treaties. Furthermore, the methodology released in the document contains the possibility for developing countries to defer the peer review, recognising their capacity constraints and often relatively small MAP pipeline. The actual peer reviews will be conducted in batches, with the first batch commencing in December 2016.
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