At its meeting of 19-23 October 2009, the UN Committee of Experts on International Cooperation in Tax Matters mandated its Subcommittee on Dispute Resolution "to consider ... [d]ifferent possible ways to improve the mutual agreement procedure (including advance pricing agreements, mediation, conciliation, recommended administrative regulations and prescribed obligations for the taxpayer applying for mutual agreement procedure)." The Subcommittee was also invited to "primarily focus on the specific needs and concerns of developing countries and countries in transition." This first draft of a Guide to the Mutual Agreement Procedure has been prepared pursuant to that part of the mandate of the Subcommittee. It is tabled at the Committee’s meeting of 18-22 October 2010 for the sole purpose of seeking written comments so that it may be subsequently revised by the Subcommittee and discussed at the 2011 meeting of the Committee. This draft has been prepared on the basis of the UN Model as it currently reads. It will be revised to take account of any changes to Article 25 and its Commentary that may be adopted at the meeting of 18-22 October 2010.

37 p. : tables

Includes bibliographical references.