The OECD announced on19 February 2019 that it is currently collecting taxpayer input in preparation for the eight batch of stage 1 peer reviews in relation to improving the tax treaty dispute resolution process under Action 14 of the project on base erosion and profit shifting (BEPS).

The countries to be reviewed in the eight batch of peer reviews are Brunei Darussalam, Curaçao, Guernsey, Isle of Man, Jersey, Monaco, San Marino and Serbia. Taxpayer input is important for the peer review process because taxpayers are the main users of tax dispute mechanisms such as the mutual agreement procedure (MAP). The OECD is therefore looking for input from taxpayers and associations of taxpayers such as business and industry associations. The information should be sent in by 19 March 2019.

Stage 1 of the peer review process is concerned with reviewing the implementation by members of the Inclusive Framework of the minimum standard under BEPS Acton 14 and the OECD requires information on specific relevant issues relating to access to the MAP; the clarity and availability of MAP guidance and the timely implementation of MAP agreements in each of the countries. A taxpayer input questionnaire is provided for the purpose of sending in information. Following the completion of the Stage 1 peer reviews reports will be issued on each country outlining recommendations for improving the dispute resolution process.

Stage 2 of the peer review process will focus on monitoring the extent to which countries have followed up any recommendations resulting from the Stage 1 reports. Peer review reports in relation to five rounds of Stage 1 peer reviews covering 37 jurisdictions have already been issued.

Membership of the Inclusive Framework gives non-OECD countries a greater chance to provide input into the BEPS process and its implementation. The member countries commit to the minimum standards under BEPS and are subject to peer reviews. The Inclusive Framework is implementing the monitoring process for the four minimum standards under BEPS and the review mechanisms for other parts of the BEPS package. The Inclusive Framework is also involved in developing various toolkits to assist developing countries in BEPS implementation.