Proposals To Improve The Efficiency Of The MAP

Having an efficient alternative dispute resolution mechanism is key for purposes of reaching the aim of double tax conventions, i.e. elimination of double taxation without creating opportunities for non-taxation or reduce taxation through tax evasion or avoidance.

Although the mutual agreement procedure (MAP) has proved its efficiency as an alternative dispute resolution mechanism for resolving international tax disputes, it has also proved its fragility and limitations. This article analyses the problems that arise from the application of the MAP and present proposals to improve the efficiency of MAP to resolve controversies under double tax agreements.

Introductory remarks