OECD seeks feedback on cross-border tax dispute resolution in eight countries

The OECD today asked taxpayers to provide feedback on their experiences with cross-border tax dispute resolution procedures in the following countries: Brazil, Bulgaria, China, Hong Kong, Indonesia, Papua New Guinea, Russia, and Saudi Arabia.

The information, to be collected in a taxpayer input questionnaire will aid a peer review of the countries’ practices for reports being prepared for approval by the “Inclusive Framework on BEPS.”

The Inclusive Framework is a coalition of 123 countries that have agreed to be bound by and review other countries’ compliance with minimum standards set out in 2015 OECD/G20 base erosion profit shifting (BEPS) plan agreements, including provisions aimed at improving tax dispute resolution.

The questions relate to the mutual agreement procedure (MAP) for resolving tax treaty disputes in the listed countries, clarity and availability of MAP guidance, and the timely implementation of MAP agreements. Feedback is requested by December 13.

During October 13 OECD webinar, Félicie Bonnet, Advisor, Mutual Agreement Procedures Unit, made a special appeal for taxpayer feedback on this 7th batch of MAP peer reviews.

Bonnet said that the peer reviews rely on stakeholder feedback on countries’ MAP practices; however, she said that this feedback has been insufficient, particularly for the later rounds.

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