Institutionalization of Mediation in State-to-State Tax Disputes

New
Journal
Author
Jung, B. (Byungsik)
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2027 (Volume 81), No. 1
FormatPDF
EUR
45
| USD
50 (VAT excl.)

Mediation could strengthen the Mutual Agreement Procedure (MAP) for state-to-state tax disputes by facilitating negotiation, accelerating resolution and preserving state control over outcomes. This article examines mediation’s compatibility with the MAP, its benefits and practical operational guidelines, arguing that institutionalization may proceed through agreed administrative procedures, treaties or multilateral protocols, under cooperation channels.