“Effective dispute resolution by the competent authorities (CAs) under the existing tax treaty procedures is an important aspect of the international law obligation of good faith implementation of a tax treaty as a whole. In particular, the Mutual Agreement Process (MAP) requires that the CAs “shall endeavour” to resolve cases in a satisfactory manner.”
Extracted from – OECD, Centre for Tax Policy & Administration, 2004 : Report on Improving the Process for Resolving International Tax
TASK:
With respect to the concepts of ‘transfer pricing’ and ‘double taxation’, critically evaluate, with reference to appropriate case law examples, the extent to which tax disputes in these areas have been resolved satisfactorily.