Resolving international tax disputes : a Canadian perspective on the work of the OECD

An analysis is made of the OECD writings on resolving international tax disputes from a Canadian perspective. The author discusses inter alia the growing international cooperation between tax authorities of different countries, access to the mutual agreement procedure, deficiency interest on disputed tax, and fact finding and legal analysis as the basis for successfully resolving mutual agreement procedures. The last part of the article deals with novel methods for resolving international double taxation, the recently concluded Memorandum of Understanding between the Canadian and US competent authorities and the question of what form the new order in this field will take.