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of <h1>Exploring Article 25: OECD and UN Models Offer Paths for Tax Dispute Resolution, Including Arbitration Options.</h1> Article 25 of the OECD and UN Model Tax Conventions addresses the Mutual Agreement Procedure (MAP) for resolving disputes where a person believes they are subject to taxation not in accordance with a tax treaty. Under the OECD Model, individuals can present their case to the competent authority of either Contracting State within three years of the disputed action. If unresolved, the issue may proceed to arbitration, unless previously decided by a court. The UN Model offers two alternatives: Alternative A mirrors the OECD without arbitration, while Alternative B includes mandatory arbitration with distinct procedural differences, such as a three-year resolution period and competent authority-initiated arbitration.
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