By Julie Martin, MNE Tax
The OECD today requested input from taxpayers to assist in an assessment of the timeliness and efficiency of the cross-border tax dispute resolution process in Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, United Arab Emirates, and Vietnam.
Taxpayers are invited to submit comments on their experiences by December 16 through filling out a taxpayer input questionnaire.
The assessment, conducted by an OECD-led group, the Forum on Tax Administration, will focus the operation of the 13 countries’ mutual agreement programs (MAPs), as set out in their tax treaties.
The Forum on Tax Administration will provide recommendations to the countries on how to improve their programs and will follow up with later reports discussing whether the recommendations were adopted or not.
Altogether, the Forum on Tax Administration intends to review and provide recommendations on the MAP programs of 79 jurisdictions between 2016 –2021. So far, 45 countries have been reviewed.
Despite the existence of MAP provisions in tax treaties, it is sometimes difficult for multinational groups to get countries to resolve instances of double taxation, which can occur when two or more countries claim taxing rights over the same income. It is expected that this assessment will encourage countries to improve their processes to resolve these disputes.
The plan to review and provide this feedback on country MAP programs was agreed to by countries as a result of the 2015 OECD/G20 base erosion profit shifting (BEPS) plan.
Julie Martin
Julie Martin is the founder of MNE Tax. She edits the publication and regularly contributes articles on new developments in cross-border business taxation.
Julie has worked as a tax journalist and editor for more than 13 years. Prior to that, she worked as an in-house tax attorney in New York. She also holds an LLM in taxation from New York University School of Law.
Julie can be reached at [email protected].
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