New Developments in Dispute Resolution in International Tax

Abstract

In October 2015, the Organisation for Economic Co-operation and Development (OECD) issued its Final Reports on all 15 areas of its Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan), with the aim of introducing comprehensive, coherent and co-ordinated reform of the international tax rules. The OECD/Group of Twenty (G20) Final report on Making Dispute Resolution Mechanisms More Effective (Final Report on BEPS Action 14) reflects the commitment of participating countries, including Australia, to implement substantial changes in their approach to dispute resolution. This article will evaluate the implications of these reforms, particularly from an Australian perspective.