Making Dispute Resolution More Effective – Simplified Peer Review, Montenegro (Stage 1)

Under BEPS Action 14, OECD/G20 Inclusive Framework members committed to implementing a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP), which helps resolve disputes over tax treaty interpretations. The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes over tax treaty interpretations and applications. The minimum standard is monitored through a peer review process, initially conducted in two stages for 82 jurisdictions, and deferred until the end of 2021 for remaining Inclusive Framework jurisdictions with no or limited MAP experience. Stage 1 assessed countries against the minimum standard according to an agreed schedule of review, while Stage 2 monitored the follow-up on recommendations of Stage 1. Following the conclusion of the initial peer review process in 2022, a continued monitoring process for all members of the Inclusive Framework was established. Jurisdictions with "meaningful MAP experience" would undergo a full peer review process every four years, while others would go through a two-stage simplified peer review process. This report reflects the outcome of Stage 1 of the simplified peer review of the implementation of the BEPS Action 14 Minimum Standard by Montenegro.