OECD经合组织：有效相互协商程序手册（2026版）（英文版）

Double taxation conventions or tax treaties typically include a specific provision dedicated to resolving disputes regarding the interpretation or application of their provisions. This provision is usually based on Article 25 of the OECD Model Tax Convention, which outlines the Mutual Agreement Procedure or MAP. The MAP offers taxpayers a means of recourse when they believe they have been taxed in a manner inconsistent with the terms of the tax treaty. For eligible cases filed under MAP by ta