2 Introduction International tax dispute prevention and resolution mechanisms have traditionally relied on bilateral negotiations between competent authorities, in the form of the Mutual Agreement Procedure(MAP), and, more recently, in the form of Advanced Pricing Agreements(APAs). These mechanisms have remained mainly unchanged since they were first designed and implemented(at the beginning of the 21 st century in the case of the MAP). Despite the historical stability of the regime, much of the developing world does not have extensive experience in the application of these mechanisms, in some cases due to there being a limited or non-existent treaty network, and in other cases due to only limited use of the mechanism by taxpayers operating in their jurisdictions. In 2015, the BEPS Action 14 Report established a minimum standard for all the Inclusive Framework (IF) members in an effort to address ongoing criticisms based mainly on the lack of finality and the uncertain duration of the MAP. This standard is currently being enforced by a peer-review system created by the Forum on Tax Administration(FTA) MAP Forum, which allows for deferral of the review for non-members of the G20 and non-members of the Organisation for Economic Co-operation and Development(OECD) that have low levels of MAP disputes. However, the OECD narrative since 2007 has been pointing towards the need to complement the MAP with mandatory binding solutions, leading to the inclusion of article 25.5 in the OECD Model Tax Convention in 2017 and of Chapter VI in the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting(MLI). Despite developing country opposition, this trend is being further advanced with the tax certainty block included in the solution proposed to address the tax challenges arising from digitalization of the economy. The agreements published in October 2021 by the G-7, G-20, and the Inclusive Framework on this topic include dispute prevention and resolution mechanisms for the first of the solutions(Pillar One), which limits source/market country taxing rights with regard to remote or digital activities in exchange for the right to tax a small portion of the excess profits made by some of the largest globalized taxpayers. The dispute prevention and resolution mechanisms will deal with potential conflicts for Amount A and“all issues related to Amount A(e.g., transfer pricing and business profits disputes), in a mandatory and binding manner.” 1 Further, it announces that“An elective binding dispute resolution mechanism will be available only for issues related to Amount A for developing economies that are eligible for deferral of their BEPS Action 14 peer review and have no or low levels of MAP disputes.” 2 Because of this last exclusion, and because developing countries have traditionally objected to mandatory binding arbitration, the design of the mechanisms agreed in October are more of a priority for the supporters of mandatory binding solutions, led by the United States and other developed economies. 1 OECD Inclusive Framework(8 October, 2021). Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. Available at https://www.oecd.org/tax/beps/statement-on-a-two-pillar-solution-to-address­the-tax-challenges-arising-from-the-digitalisation-of-the-economy-october-2021.pdf P.2.(last accessed on 21.2.2022) 2 Ibidem. This opt-out mechanism is only available for non-OECD, non-G-20 countries.