Policy Brief

7

What Have We Learned About International Tax Disputes?

This publication is also available in French

What Have We Learned About International Tax Disputes?

This Briefing summarises ICTD Working Paper 55, which examines the Mutual Agreement Procedure (MAP) for tax authorities to resolve their differences over the interpretation of tax treaties. It surveys available evidence on reasons for the increase in such conflicts, and analyses proposals for improving the MAP, especially mandatory binding arbitration. Despite the shift to arbitration in the past decade among Organisation for Economic Cooperation and Development (OECD) states, there has been a continued rise in conflicts and in the time taken to resolve them. It seems inappropriate, especially for developing countries, to deal with these important issues through international procedures cloaked in total secrecy. A better approach would be to aim to minimise conflicts by developing clear and simple rules for apportioning the income of integrated transnational corporations (TNCs), and agreeing interpretations of tax treaty provisions that can be made public. Greater transparency is the best way to provide the clarity and predictability that business needs, and to reassure the public that decisions on international taxation are fair.

Publication Details

Date

Publisher

Research theme

Share

More resources

Authors

Related Publications

Journal Article

Relieving Double Taxation on Cross-Border Services: A Comparative Analysis of Major Exporting Countries

July 2026
Frederik Heitmüller, Aisha Aize Isa, Florian Dierich, Yvette Nakibuule Wakabi

Research in Brief

Global Rules, Local Realities: Lessons from the Global South on International Tax Standards

June 2026
Martin Hearson, Frederik Heitmüller, Florian Dierich

Working Paper

Global Rules, Local Challenges: Peru’s Adoption of International Tax Standards

December 2025
Katia Toledo Ruiz

Working Paper

Taxing Choices: Reconciling Global International Tax Standards with Pakistan’s Domestic Tax Realities

December 2025
Muzammal Rasheed