Expediting Tax Dispute Resolution

 Expediting Tax Dispute Resolution 

 

Consensus to be implemented:

 

1. We will endeavor to provide taxpayers with good access to dispute resolution mechanisms including administrative reconsideration of assessments, legal remedies, mutual agreement procedure (hereinafter referred to as “MAP”) as provided for by tax treaties and other necessary complementary remedies.

 

2. We will conduct a survey to better understand cross-border tax disputes in the BRI jurisdictions by collecting further information on the types and causes of disputes; taking stock of the current procedures to resolve BRI tax disputes and recognizing the benefits and main deficiencies therein; and identifying good practices in BRI jurisdictions. 

 

3. Recognizing the resource and constraints faced by tax administrations, we wish to consider a staged approach for minimizing and resolving tax disputes. The following are the actions to take in the coming two years. 

 

- Establishing clear internal tax administrative procedures to ensure that there are clear and consistent interpretations of laws and regulations; 
- Strengthening MAP functions with dedicated personnel; 
- Drawing up a list of MAP contact points in the BRI tax administrations and publishing it on the BRITACʘM website; 
- Ensuring taxpayer’ s accessibility to MAP; 
- Extending tax treaty networks; 
- Holding workshops to facilitate the negotiation and interpretation of tax treaties; 
- Adapting MAP and improving relevant procedures to the situations found in the BRI jurisdictions; and 
- Endorsing the minimum standards proposed under the Base Erosion and Profit Shifting (hereinafter referred to as “BEPS”) Action 14. 
 

 

 

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