US And OECD Officials Discuss Tax Dispute Resolution

by Mike Godfrey, for LawAndTax-News.com, Washington

20 January 2005

At a conference held last Friday in Washington, OECD and US officials discussed ways to improve the resolution of cross-border tax disputes, according to reports.

Director of the Centre for Tax Policy and Administration with the Organisation for Economic Cooperation and Development, Jeffrey Owens explained that the discussions were considered necessary because since 2002 there has been an "increase in the number and complexity of cross-border disputes - primarily in transfer pricing".

He went on to stress that the OECD is committed to improving the mutual agreement procedure (MAP) contained within the model tax convention, possibly by increasing access for those involved in a dispute to mediation or arbitration services.

However, he observed that improving the procedure may not be straightforward, because "some countries are not convinced the system is broken and other countries may have constitutional issues".

Meanwhile, international director of the US Internal Revenue Service's Large and Midsize Business Division, Robert Green reportedly urged the need for caution in attempts to increase the transparency of dispute resolution procedures, explaining that the IRS has an important duty to protect taxpayer privacy.

Recommended