These three sections of the publication are each authored by a different expert. The first section delves into contemporary debates surrounding the MAP, with a particular focus on its application in developing countries and the implications of the OECD’s BEPS Action 14 proposals. The second section explores international tax arbitration, providing an overview of its evolution, the challenges it presents, and its impact on global tax governance. The final section offers forward-looking reflections on the role of mediation in international tax, evaluating its potential as a complementary or alternative tool for dispute resolution.

Part 1. Contemporaneous Debates for MAP Regulations in Developing Countries

(Focus on the Colombian Experience)

Part 2. International Tax Arbitration: What it Means and How it Has Evolved

Part 3. Prospective Reflections on Mediation in the International Tax Context