Is the Mutual Agreement Procedure Past Its “Best-Before Date” and Does the Future of Tax Dispute Resolution Lie in Mediation and Arbitration?

Journal
Sidhu, P.K.
International
Bulletin for International Taxation 2014 (Volume 68), No. 11
PriceUSD 45

This article examines dispute resolution mechanisms under tax treaties and bilateral investment agreements, with a particular focus on mutual agreement procedure (MAP). It concludes that the MAP is not efficient at dispute resolution and more attention should be paid to alternative methods of dispute resolution, such as arbitration and mediation.