On 18 November 2019 the OECD invited interested parties to submit input in relation to the tenth batch of dispute resolution peer reviews. Information should be submitted to the OECD by 16 December 2019 using the taxpayer input questionnaire. The views of taxpayers on the relevant issues are important for the peer reviews as businesses are the main users of the tax treaty dispute resolution process.

Information is requested in relation to reviews of Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, United Arab Emirates and Vietnam.

Action 14 of the BEPS project is concerned with improving the process of tax dispute resolution. The peer reviews of each country are being conducted in two stages, with stage 1 assessing the implementation of the OECD minimum standard and stage 2 monitoring the implementation of recommendations made in the report on stage 1.

Following the issue of reports on base erosion and profit shifting (BEPS) by the OECD in 2015 the improvement of the tax treaty dispute resolution process has been one of the main priorities of the ongoing BEPS Project. The peer review and monitoring process in relation to the mutual agreement procedure (MAP) under BEPS Action 14 began in December 2016 and is covering issues such as access to the mutual agreement procedure; availability of clear MAP guidance; and timely implementation of the outcomes of the MAP.

The agreed reporting framework under BEPS action 14 sets out common definitions of a MAP case and details of the start date, end date and outcome. These definitions are now used for counting MAP cases and for calculating the average time needed to close a case. The statistics also show the types of cases concerned and the outcomes reached. The minimum standard under action 14 requires jurisdictions to try to resolve mutual agreement procedure (MAP) cases within 24 months on average. Around 65 member countries of the Inclusive Framework on BEPS are now reporting their MAP statistics under an agreed reporting framework.