Tax treaty dispute resolution: lessons from the law of the sea

The mutual agreement procedure (MAP) needs improvement to address the tsunami of international tax disputes expected in the international tax regime (ITR) over the next decades. Using the dispute resolution system under the law of the sea regime as a benchmark, this thesis submits a proposal to restructure the MAP system for improving dispute resolution in the ITR. This comparative analysis is premised on certain geopolitical similarities that underpin both international regimes and comparative institutional analysis grounds the theoretical framework. The proposed reform expands the MAP system by introducing three new mechanisms to form a comprehensive legal framework for addressing all tax treaty-related disputes. It recommends specific consensus-building techniques to facilitate the implementation of the proposal across the G20/OECD inclusive framework (IF) through consensus in both the developed and developing worlds.