Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits...

This book analyzes the role banks play in the provision of aggressive tax planning arrangements. It examines the nature of banking, the complex structured financing transactions developed by banks and how they are then used by both banks and their clients. It also explores the internal...