Tax risks of multinational enterprises are expected to continue to increase post-BEPS (Base Erosion and Profit Shifting) as tax authorities globally increase their scrutiny on their cross-border tax transactions.

This trend is anticipated in the OECD/G20 BEPS Action Plan: one of the Actions in it attempts to complement efforts to address BEPS with measures that ensure certainty and predictability for businesses in the face of increased tax controversy risks.

Action 14 of the BEPS Action Plan, in particular, seeks to improve the effectiveness of the mutual agreement procedure (MAP) in resolving treaty-related and transfer pricing disputes.

To learn more about what a MAP is, who can access MAP, why you should consider using MAP, and whether MAP is a viable alternative for dispute resolution, please read our Global Tax Alert.