Improving dispute resolution mechanisms is an integral component of the work on BEPS.
The measures developed under Action 14 of the BEPS Project and contained in this report
aim to minimize the risks of uncertainty and unintended double taxation. They do so
by ensuring the consistent and proper implementation of tax treaties, including the
effective and timely resolution of disputes regarding their interpretation or application
through the mutual agreement procedure. Countries have agreed to important changes
in their approach to dispute resolution, such as a minimum standard with respect to
the resolution of treaty-related disputes. They have committed to its rapid implementation
and agreed to ensure its effective implementation through the establishment of a robust
peer-based monitoring mechanism. A large group of countries has also committed to
provide for mandatory binding arbitration in their bilateral tax treaties as a mechanism
to guarantee that treaty-related disputes will be resolved within a specified timeframe.
Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid.