The mutual agreement procedure is a well-established means through which tax administrations consult to resolve disputes regarding the application of double tax conventions. This procedure, described and authorised by Article 25 of the OECD Model Tax Convention, can be used to eliminate double taxation that could arise from a transfer pricing adjustment. (Members of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) have agreed to a minimum standard with respect to the resolution of treaty-related disputes. This Section C of Chapter IV is not intended to be an explanation of the minimum standard, and thus there is no implication that all members of the Inclusive Framework are in agreement with the guidance contained in this section, except where a particular statement is explicitly identified as an element of the minimum standard. The minimum standard has three general objectives: (1) jurisdictions should ensure that treaty obligations related to the mutual agreement procedure are fully implemented in good faith and that MAP cases are resolved in a timely manner; (2) jurisdictions should ensure that administrative processes promote the prevention and timely resolution of treaty-related disputes; and (3) jurisdictions should ensure that taxpayers that meet the requirements of paragraph 1 of Article 25 can access the mutual agreement procedure. The detailed elements of the minimum standard are set out in OECD (2015), Making Dispute Resolution Mechanisms More Effective, Action 14 – 2015 Report, OECD/G20 BEPS Project, OECD Publishing, Paris. The minimum standard is complemented by a set of best practices (to which not all members of the Inclusive Framework have committed) that respond to the obstacles that prevent the resolution of treaty- related disputes through the mutual agreement procedure. In addition, although there is currently no consensus among all members of the Inclusive Framework on the adoption of mandatory binding arbitration as a mechanism to ensure the timely resolution of MAP cases, a significant group of countries has committed to adopt and implement mandatory binding arbitration.) ...