Tax Disputes Prevention and Resolution and Tax (Un)certainty: Two Interconnected Concepts within the Frame of the BEPS Action Plan

The present study refers to two interconnected concepts, namely tax disputes prevention
and resolution and tax (un)certainty. The study examines the international tax dispute
resolution framework and more particularly Action 14 of the OECD Action Plan on the
Mutual Agreement Procedure (»MAP«) as well as the prevention and resolution of tax
disputes within the framework of the OECD Action Plan 2.0. Furthermore, the study also
focuses on Council Directive (EU) 2017/1852 on tax dispute resolution mechanisms in the
European Union, as the EU answer towards tax uncertainty in the field of tax dispute
resolution.