The effectiveness of the Mutual Agreement Procedure and the global tax controversy landscape: some critical observations on current pressure areas and suggestions to improve the framework - Kluwer International Tax Blog

The effectiveness of the Mutual Agreement Procedure and the global tax controversy landscape: some critical observations on current pressure areas and suggestions to improve the framework - Kluwer International Tax Blog

Introduction On 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax Policy Center of the University of Lausanne and the Singapore Tax Academy. While acknowledging the progress made since the adoption of BEPS Action 14 in relation to the mutual agreement procedure (“MAP”) of tax treaties, we observed (at least based o…