Dispute resolution


  • BEPS Action 14 peer review and monitoring

    In October 2016, the OECD released key documents, approved by the Inclusive Framework on BEPS, that will form the basis of the MAP peer review and monitoring process under Action 14 of the BEPS Action Plan. The peer review and monitoring process will be conducted by the Forum on Tax Administration MAP Forum in accordance with the Terms of Reference and Assessment Methodology, with all members participating on an equal footing.

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  • 2022 MAP Statistics

    Under Action 14 of the BEPS Action plan, jurisdictions have committed to report mutual agreement procedure (MAP) statistics pursuant to an agreed reporting framework in a timely and complete manner.

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  • APA Statistics

    To build upon the progress that has been achieved in the area of Advance Pricing Arrangements (APAs) through the Bilateral Advance Pricing Arrangement Manual (BAPAM), all BEPS Inclusive Framework member jurisdictions that have an APA programme have committed to start reporting annual APA statistics.

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International double taxation may result where two jurisdictions seek to tax the same transactions or activities. Whilst tax treaties directly resolve most such cases, international double taxation may remain where two jurisdictions disagree on the interpretation or application of a treaty provision. The mutual agreement procedure (MAP) article of a tax treaty accordingly provides a mechanism to resolve these cross-border tax disputes.



One of the elements of the BEPS Action 14 minimum standard requires jurisdictions to seek to resolve mutual agreement procedure ("MAP") cases within an average timeframe of 24 months. To monitor compliance with this element, members of the Inclusive Framework on BEPS have committed to report their MAP statistics pursuant to an agreed reporting framework. Read more