Monday, November 25, 2019
The OECD is seeking input from taxpayers on dispute resolution mechanisms in place in Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, the United Arab Emirates, and Vietnam, as part of follow-up work under BEPS Action Plan Action 14.
Improving the tax treaty dispute resolution process is a top priority of the BEPS Project. The Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan was launched in December 2016, with the peer review process of the first nine batches now underway. Input is now being sought on the tenth batch of peer reviews.
The peer review process is conducted in two stages. Under Stage 1, implementation of the Action 14 minimum standard is evaluated for Inclusive Framework members. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 report.
The OECD is now gathering input for the Stage 1 peer reviews of the aforementioned territories. In particular, the OECD wants to hear from taxpayers about specific issues relating to access to MAP, the clarity and availability of MAP guidance, and the timely implementation of MAP agreements for each of the jurisdictions.
Taxpayers doing business in these territories are being encouraged to complete a questionnaire by December 16, 2019, at the latest.