Consensus to be implemented：

1. We will endeavor to provide taxpayers with good access to dispute resolution mechanisms including administrative reconsideration of assessments, legal remedies, mutual agreement procedure (hereinafter referred to as “MAP”) as provided for by tax treaties and other necessary complementary remedies.

2. We will conduct a survey to better understand cross-border tax disputes in the BRI jurisdictions by collecting further information on the types and causes of disputes; taking stock of the current procedures to resolve BRI tax disputes and recognizing the benefits and main deficiencies therein; and identifying good practices in BRI jurisdictions. 

3. Recognizing the resource and constraints faced by tax administrations, we wish to consider a staged approach for minimizing and resolving tax disputes. The following are the actions to take in the coming two years.