The Ombudsman and the Process of Resolution of International Tax Disputes – Protecting the “Invisible Party” to the MAP

Abstract

This article explores the possible involvement of tax specialist ombudsmen in the mutual agreement procedure (MAP). With the current level of development of the MAP still facing criticism for a lack of efficiency and transparency, and the arbitration only being adopted by a handful of states, alternative solutions should be considered in order to enhance the MAP, while adequately protecting taxpayer rights.