Mutual Agreement Procedure (MAP) peer review – UK

Action 14 of the OECD BEPS Action Plan was designed to streamline dispute resolution when there is disagreement between the countries that are party to a double tax agreement as to the implications in a particular set of facts and circumstances, for instance which country has the taxing rights. The Mutual Agreement Procedure (MAP) is the mechanism whereby such disputes are resolved but after BEPS there were concerns that there would be more disputes and Action 14 was designed to streamline the process.

OECD set up a peer review process Mutual Agreement Procedure (MAP) peer review and monitoring process  to determine what is going on in individual countries and to ensure that where improvements are necessary they will be made. UK was in the first batch of six countries to have their MAP processes reviewed and reported on and the first stage of the UK report was published at the end of September 2017 Making Dispute Resolution more effective – MAP Peer Review Report UK – Stage 1