The OECD has today published peer review reports that assess the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom.
The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to implement “minimum standards” developed and agreed to by OECD and G20 countries as a result of the base erosion profit shifting (BEPS) plan.
One such minimum standard, in BEPS Action 14, is a commitment by countries to ensure that they resolve tax treaty-related disputes in a timely, effective, and efficient manner.
The OECD said in a release today that the six reports include over 110 recommendations relating to the minimum standard. Overall the six counties “performed well,” the OECD said.
One problem area is that some countries are having difficulty resolving mutual agreement procedure (MAP) tax treaty cases within a time frame of 24 months or less, especially when the dispute concerns transfer pricing, the OECD said.
Each of the six jurisdictions was also given recommendations on how to align their tax treaty MAP provisions with the Action 14 minimum standard.
Also, some countries needed to make their MAP guidance more clear, the OECD said.
International businesses were asked last October to report any grievances they had about the MAP program in the countries assessed to assist in the review.
A later peer review will assess each country’s progress in addressing the shortcomings identified in this first stage peer review report. That assessment will be launched one year from today.
The inclusive framework intends to launch assessments of 60 countries through 2019. Next up for stage one review will be Austria, France, Germany, Italy, Liechtenstein, Luxembourg, and Sweden.
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