Subcommittee on Dispute Resolution
- Status: Active
- Coordinator: Ms. Claudine Devillet (Belgium)
a) Different possible ways to improve the mutual agreement procedure (including advance pricing agreements, mediation, conciliation, recommended administrative regulations and prescribed obligations for the taxpayer applying for mutual agreement procedure).
b) The possibilities to provide for arbitration (either in the United Nations Model Convention Articles or as an alternative in the Commentaries); in this respect both mandatory and voluntary arbitration shall be considered as well as streamlined arbitration.
c) Possible specific problems and needs with respect to transfer pricing dispute resolution. In doing so, the Subcommittee shall primarily focus on the specific needs and concerns of developing countries and countries in transition. The Subcommittee shall present a report, with draft provisions and Commentaries annexed, during the next annual session of the Committee for consideration and further guidance.
- Creation: Fifth session of the Committee (October 2009)
- Output: A new Article 5 and Commentary were proposed.