Mutual Agreement Procedures in Tax Treaties: Problems and Needs in Developing Countries and Countries in Transition - Intertax View Mutual Agreement Procedures in Tax Treaties: Problems and Needs in Developing Countries and Countries in Transition by - Intertax Mutual Agreement Procedures in Tax Treaties: Problems and Needs in Developing Countries and Countries in Transition 42 3

Mutual agreement procedure is a key tool that need to be strengthened in order to reduce unresolved treaty-related disputes, while providing certainty and predictability for business. Competent authorities need to improve the effectiveness of this mechanism, facing many obstacles that prevent them from solving disputes in due time. This article describes some problems that, additionally, competent authorities in developing countries have to address to perform their function, particularly those related to the organization itself, which may prevent them from considering arbitration as an alternative dispute resolution mechanism to deal with disagreements in the course of MAP cases.

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