This article contributes to the literature by questioning the efficacy of the MAP for the resolution of international tax disputes from a developing country perspective. It contends that the MAP in its very basic form is insufficient for resolving treaty disputes and that the Organization for Economic Cooperation Development’s (OECD’s) portrayal of theMAP’s success is misleading. This article also proposes a consideration of theMAP’s efficacy to resolve tax treaty disputes as it relates to treaties between developed countries such as the United States and those underdeveloped like Nigeria. It concludes that the MAP alone cannot effectively resolve treaty disputes without it being accompanied by arbitration. It further argues that, even when the latter occurs, it will not create a workable dispute resolution mechanism in any absolute terms.