Mapping the trends in MAP resolution of tax treaty disputes after BEPS

Global Transfer Pricing

A presentation on the improvements BEPS has made to the resolution of international tax disputes through the Mutual Agreement Procedure (MAP) under tax treaties. TPA Global has initiated a series of webinars covering the global impact of emerging BEPS developments on various international structures.

In the 3rd webinar of this series, we will analyze if the improvements made under BEPS indeed result in a MAP procedure becoming more attractive for taxpayers to pursue, either instead of, or, as the case may be, next to domestic litigation.

Key Highlights of the webinar:

  • Presentation of the following elements of BEPS dealing with MAP and MAP arbitration:
    • Action 14 – Making Dispute Resolution Mechanisms More Effective;
    • Part V – Improving Dispute Resolution, MAP and Corresponding Adjustments, and Part VI - Arbitration of the MLI;
    • 2017 Update of Art 25 – MAP of the OECD Model and its Commentary.
  • Presentation of three landmark court cases on MAP:
    • India and simultaneous MAP and domestic court procedures (‘e-Funds’ case);
    • Denmark and refusal of MAP access on grounds of allegedly insufficient taxpayer information;
    • The Netherlands and generic application to similar cases of the result of an individual MAP case.


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