As a result of the BEPS reforms, the OECD acknowledges that the use of POPs will increase as a result of increased audit activities by tax administrations around the world. Over the past five years, the OECD has been committed to making the map process more efficient and efficient and accessible to taxpayers. The following are important elements to take into account in understanding the status of the manual and its interaction with other OECD guidelines: in addition to these developments, taxpayers residing in EU Member States have benefited from the benefits of the EU Arbitration Convention. The agreement, which was a landmark at the time of its drafting in 1990, has benefited from a series of updates drawn up by the EU Joint Forum on Transfer Prices and has been anchored in the EU`s Soft-Law by various codes of conduct adopted by EU Member States. However, the convention has always been agitated in the EU canon and has not been an EU regulatory instrument. This fundamental problem was addressed in 2019 by the European Arbitration Directive, a more formal and extensive instrument than the Convention, which effectively replaces it. In recent years, the OECD has continued its momentum and implemented the various measures outlined in the final report. The peer review and follow-up process, for example, aims to hold countries to account in their desire to streamline both the map process and to carry out other map files. The Online Manual on Effective Agreement Procedures between the Two (MEMAP) also outlines the OECD`s determination to continuously improve the POP process and its functionality, promote greater consistency in the handling of POP issues, and improve the speed and efficiency of the process. In view of the POP resolution, Part VI of the MLI (Articles 18-26) refers to the mandatory arbitration procedure for MAP files. At the time of the final report, several legal systems committed to implementing mandatory POPs arbitration procedures in their bilateral tax treaties. This section is practically optional. The process of mutual unification (POP) remains the most widely used way and the best way to eliminate double taxation.

The effective use of PPIs by different instruments has been of interest to the OECD and the EU for more than 20 years. According to bePS, the number of double taxes is increasing and the number of POPs continues to increase. There is a growing emphasis on ensuring better dispute resolution techniques to more effectively eliminate double taxation. This article describes some of the features of the instruments currently available. The MLI is an important instrument for the OECD`s ability to implement Action 14. The MLI is practically a multilateral treaty that allows jurisdictions to rapidly amend their bilateral tax treaties to implement the relevant recommendations of the OECD/G20 BEPS package. As OECD Secretary-General Angel Gurria said, “The MLI has the effect not only of saving jurisdictions from the burden of bilateral renegotiation of these treaties, but also of enhancing security and predictability for businesses and improving the functioning of the international tax system for the benefit of our citizens.” In particular, Article 19 of the compulsory arbitration procedure must be mandatory if the competent authorities are unable to reach an agreement on the settlement of a case within two years of their start. This is a significant restriction on POPs cases in the past, as the competent authorities were only required to try to resolve cases and disputes could be resolved indefinitely. Section 19 ensures that treaty disputes will be resolved within a specified time frame, making the MAP a more attractive option for taxpayers. In addition, sections 20 to 25 provide for the practical functioning of arbitration. In the past, it was often practical constraints or a lack of agreement on how to proceed that blocked the solution.

The Arbitration Directive came into force on 1 July 2019 and applies to disputes that occurred during a financial year that occurred on 1 January 2018, while the relevant