Treaties & certainty / Working reference
BEPS Action 14 — Dispute Resolution
The BEPS Action 14 report on making treaty-related dispute-resolution mechanisms more effective.
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The T&M reading note
Why it deserves your time
Explains the policy foundation of the mutual agreement procedure minimum standard.
A suggested 15-minute first pass
Where to begin
- Read the minimum-standard framework.
- Identify the taxpayer access and case-resolution themes.
- Compare with later MAP guidance and the relevant treaty.
Read this edition in context
Foundational 2015 report. Later manuals and peer reviews complement this text.
These notes describe the publication; they do not determine the treatment of a particular taxpayer or transaction.
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Official sourcewww.oecd.org Catalogue review: 2026-10-13