Possible improvements to the MAP

A country that concludes a tax treaty that includes provisions based on those of Article 25 of the United Nations or OECD model has a legal obligation to endeavour to resolve through MAP any admissible case presented to its competent authority under paragraph 1 of that article. Many developing countries, however, have no or little experience with MAP and may therefore need assistance in dealing with MAP cases, which requires not only a good understanding of the MAP process but also of treaty provisions and transfer pricing principles. Even countries with significant MAP caseloads may experience difficulties in resolving MAP cases with some of their treaty partners.

Sustainable Development Goals:

Decent Work and Economic Growth