Multinationals asked to assess MAP tax dispute resolution in US, UK, Belgium, Canada, Netherlands, Switzerland

The OECD has today asked international business to report grievances about the mutual agreement procedure (MAP) for resolving cross-border tax disputes in the US, UK, Belgium, Canada, Netherlands, and Switzerland.

The OECD seeks responses to a questionnaire by November 28 concerning taxpayer access in these countries to MAP, the clarity and availability of MAP guidance, and whether MAP agreements are implemented in a timely manner.

The comments will be used to assist the “BEPS inclusive framework,” a group of 84 countries that have committed to adopt and assist in the implementation the base erosion profit shifting (BEPS) project output.

The group will conduct a peer review of compliance with BEPS minimum standards for resolving tax treaty disputes, beginning this December with the US, UK, Belgium, Canada, Netherlands, and Switzerland.

The group’s Stage 1 peer review will determine whether the countries have the legal framework to apply the BEPS minimum standards and whether they actually apply the standards.

Altogether, the plan calls for 62 countries to be assessed through 2019.

The plan also calls for peer review to be deferred for the following developing countries, at least until until at least 2020: Benin, Costa Rica, Egypt, Gabon, Georgia, Jamaica, Kenya, Pakistan, Paraguay, Senegal, Seychelles, and Uruguay.

See:

• Questionnaire

• Schedule of reviews

Related MNE Tax articles:

• OECD plan to assess countries’ tax treaty MAP programs approved by BEPS “inclusive framework”