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

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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
Pages (from-to)656 – 673
Number of pages18
Issue number8/9
Early online date1 Aug 2021
Publication statusPublished - 1 Aug 2021


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


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