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

Qiang Cai* (Corresponding Author), Spyridon E. Malamis

*Corresponding author for this work

Research output: Contribution to journalArticlepeer-review


The mutual agreement procedure (MAP) has long been criticized. From the perspective of transaction cost theory, the deficiencies of the mechanism primarily reflect three types of transaction costs: agency cost, bargaining cost, and administrative cost, all of which can be economized via the digitalization of international tax dispute resolution (ITDR) processes. The impetus for the development of digital ITDR becomes more prominent considering the current Covid-19 pandemic. Furthermore, compared with dispute resolution mechanisms in many other domains, the ITDR process particularly lends itself to digital facilitation. However, data from peer review reports under Action 14 of the Base Erosion and Profit Shifting (BEPS) Project shows that the international practice of the digital ITDR still remains at a rudimentary stage. This underdevelopment can largely be attributed to a decentralized approach to the ITDR development at the international level. In this regard, it is proposed that the OECD can play a greater role in leading and coordinating the development of digital ITDR at the global level. In particular, a global digital platform is envisaged to facilitate the digital ITDR processes among competent authorities.
Original languageEnglish
Publication statusAccepted/In press - 17 May 2021


  • Digitalization
  • international tax dispute resolution
  • online dispute resolution
  • Covid-19
  • new technologies
  • digital justice
  • mutual agreement procedure

Fingerprint Dive into the research topics of 'Digitalization of International Tax Dispute Resolution: Reflection in Light of the Covid-19 Pandemic'. Together they form a unique fingerprint.

Cite this