Applying Modern, Disruptive Technologies to Improve the Effectiveness of Tax Treaty Dispute Resolution (Part 2)

Christina Dimitropoulou, Sriram Govind, Laura Turcan

Publikation: Wissenschaftliche FachzeitschriftOriginalbeitrag in FachzeitschriftBegutachtung


n Part 1 of this article, the authors analysed the main drawbacks of the existing tax treaty dispute resolution process and considered the
fundamental features of the main types of disruptive technology, keeping in mind how they could improve this process.
In this part, the authors make some specific suggestions as to how the analysed technologies can be used to improve the mutual agreement procedure
(MAP) and supplementary solutions. This will include the use of video conferencing to cut costs and speed up resolution (section 2); electronic filin
checking of the MAP request with respect to documentation requirements (section 3); automatic notification as regards the deadline before arbitrat
ion is
triggered and automatic forwarding of the request and any supplementary information to the other competent authority(ies); automatic notificatio
the taxpayer of each material step taken in the resolution of the case (without providing access to secure data); communication and exchange of
information between competent authorities via secure electronic means in real time; and information storage in secure shared-data platforms
(i.e. controlled access) allowing access to competent authorities and even to the arbitral panel, where required (section 3); the use of data analyti
to cluster cases by type, allowing for easier inventory management, and to generate risk profiles that could help in both the prevention of MAP cases an
the speedier resolution thereof (section 4); the use of artificial intelligence to review past cases, thereby allowing easier assignment to case wor
depending on their schedule, and thus, easier and more timely solutions based on precedents (section 5); and the use of blockchain to validate
transactions and information and to remove the need for trust, thus allowing for an easier and quicker resolution, especially in multilateral cases
(section 6).
Seiten (von - bis)960 - 970
PublikationsstatusVeröffentlicht - 2018