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The OECD is seeking taxpayers' input on the mutual agreement procedure (MAP) frameworks in place in the third batch of countries that will now be peer reviewed under Action 14 of the OECD's base erosion and profit shifting Action Plan: the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain.
The OECD's Action 14 proposals concern making dispute resolution mechanisms more effective.
The MAP is used to settle disputes between countries and taxpayers concerning cross-border tax arrangements for trade and investment where double taxation of the same income occurs.
The MAP peer review and monitoring process under BEPS Action 14 was launched in December 2016, with the first peer reviews of frameworks in Belgium, Canada, the Netherlands, Switzerland, the UK, and the US underway. The peer review process is conducted in two stages: stage 1 seeks to evaluate implementation of the Action 14 minimum standard for Inclusive Framework members, and stage 2 focuses on monitoring how countries respond to recommendations resulting from Stage 1.
The OECD has invited input from taxpayers, as the main users of the MAP in the aforementioned countries, asking them to complete a questionnaire on specific issues relating to access to MAP, clarity, and availability of MAP guidance, and whether the implementation of MAP agreements is timely in these jurisdictions.
Responses to the questionnaire must be received by July 7, 2017.
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