Allan Cinnamon provides an update on tax treaty developments
The OECD’s discussion draft on BEPS action 14 published on 18 December 2014 acknowledges that there needs to be a commitment to improve the mutual agreement procedure (MAP) in light of the number of treaty disputes that could arise as a result of BEPS. There is no consensus on moving towards universal binding arbitration in view of sovereignty issues and practical considerations. Just before the publication of the draft the OECD released its report on MAP statistics for 2013. This highlighted the need for improvement of the process: there were 4 566 MAP cases outstanding among OECD member countries alone taking an average of two years to resolve.
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