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The Mutual Agreement Procedure: A taxpayers' tool reinvented


Tax risks of multinational enterprises are expected to continue to increase post-BEPS 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. This article examines the trend.