UK and USA among six jurisdictions subject to peer reviews on implementation of BEPS

Oct 02, 2017

The OECD has released the first analysis of individual country efforts to improve dispute resolution mechanisms.  The peer review reports relate to implementation of BEPS Action 14 by Belgium, Canada, the Netherlands, Switzerland, the United Kingdom and the United States.

The six reports include over 110 recommendations relating to the minimum standard. In stage two of the peer review process, each jurisdiction’s efforts to address any shortcomings identified in its stage one of the peer review report will be monitored. The main areas where improvements are necessary concern:

  • Resolution of mutual agreement procedure (MAP) cases within 24 months is a challenge for some jurisdictions, especially concerning transfer pricing cases;
  • MAP guidance is generally clear and accessible, however improvements for some jurisdictions are necessary and already under way; and
  • Each of the six jurisdictions was given recommendations to align their tax treaty MAP provisions with the Action 14 minimum standard.