Digitalization of International Tax Dispute Resolution: Reflection in Light of the Covid-19 Pandemic

The mutual agreement procedure (MAP) has long been criticized. From the perspective of transaction cost theory, deficiencies mechanism primarily reflect three types costs: agency cost, bargaining and administrative all which can be economized via digitalization international tax dispute resolution (ITDR) processes. impetus for development digital ITDR becomes more prominent considering current Covid-19 pandemic. Furthermore, compared with mechanisms in many other domains, process particularly lends itself to facilitation. However, data from peer review reports under Action 14 Base Erosion Profit Shifting (BEPS) Project shows that practice still remains at a rudimentary stage. This underdevelopment largely attributed decentralized approach level. In this regard, it is proposed OECD play greater role leading coordinating global particular, platform envisaged facilitate processes among competent authorities. Digitalization, resolution, online Covid-19, new technologies, justice, procedure.