http://midequalitygroup.co.uk/events/list/?tribe-bar-date=2021-09-09 Overall, it is clear that the MLI extends taxpayers` access to three years, both in terms of extending the period during which taxpayers must initiate a POB period, provides an effective two-year period for the relevant authorities to resolve a case (after that date, it may be subject to arbitration). The MLI has led to a greater homogeneity of approach on key issues such as arbitration and, above all, the adoption of a single map article for covered tax treaties. Even in the event of an arbitration request, the EU review found that there could be many shortcomings in the system, including delays or lack of setting up the advisory committee and the lack of agreement on the appointment of the chairman of the advisory committee that delays or prevents the procedure. 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. In addition to these developments, taxpayers 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. OECD statistics on POPs show that more taxpayers are using the map procedure, given the increase in bilateral tax controls and disputes.
The MLI has helped to improve the efficiency and effectiveness of the map process, in line with the intentions expressed in the final report of 5 years ago.