Institutionalization of Mediation in State-to-State Tax Disputes

This is the authors' abstract. We don't add key points for this paper.

Mediation could strengthen the Mutual Agreement Procedure (MAP) for state-to-state tax disputes by facilitating negotiation, accelerating resolution and preserving state control over outcomes. This article examines mediation’s compatibility with the MAP, its benefits and practical operational guidelines, arguing that institutionalization may proceed through agreed administrative procedures, treaties or multilateral protocols, under cooperation channels.