A Highlight of Key Areas:
- Objectives of BEPS Action 14 and global standards on dispute resolution, including Peer Review Mechanism
- Scope of the MAP (including as the case may be tax treaty arbitration): what is inside and outside the MAP
- Access/ denial of MAP requests
- Judicial review in relation to the denial of access to MAP and information access
- Possible improvements to the OECD Commentary on Art. 25 to better align the practice to the objectives of BEPS Action 14
- Singapore tax treaty dispute resolution policy and practice and standards laid down by BEPS Action 14
- Perspective and experience with tax treaty arbitration
- Current experiences: (i) increase or decrease of MAP cases/ country(ies) with the most important number of MAP cases, (ii) experiences with developing countries
- Challenges raised by capacity building
- Singapore's perspective on the handling of P2 disputes
- Perspective of business on the above inputs