10 developing country opposition to international tax arbitration.16 Furthermore, there is a perceived disadvantage for developing countries because of the taxpayer financial resources that usually contribute to the parent entity position rather than the market entity position. Some of the costs can be reduced by the implementation of efficiency measures, such as cutting in­person meetings to the minimum necessary and taking advantage of virtual communications technology. In the case of the dispute resolution mechanism, if there is a plural number of cases in a single year involving the same parties, an accumulation of cases with similar issues should be allowed in order to reduce costs. The cost allocation mechanism contemplated in article 25 in Part VI of the MLI creates a high degree of inequality when the costs are expressed as a percentage of GDP, especially for smaller and developing countries. Besides, the costs for legal fees are known to be the highest,17 and therefore developing countries will be at a disadvantage, if each country is to pay for the panel member that they nominate. This inequality will result in developed countries nominating costly experts while developing countries stick to competent authorities because of the costs of hiring an independent expert who could successfully counter the views of the expert retained by the developed country. This may have serious consequences in practice, since it is highly likely that the independent expert voice will dominate the panel discussion and will steer the decision in one direction. On the other hand, a full exemption from all costs would be strategically unrealistic, as it would reduce developing country rights to participate in stakeholder decision processes, and it could even encourage extreme audit positions if there are no costs associated with defending this position. One possible solution to reduce the impact of costs for G-24 countries and to introduce a differential focus for developing countries is to establish total cost procedures for each determination, review, or resolution panel in which a developing country is to participate, and then split the costs proportionately to GDP amongst all participating countries. These costs would have to include every expense related to the procedure, including panel member fees, expert witness fees, translations, travel costs, and any administrative fee charged by the administering body. This would in practice result in the majority of costs being borne by the developed countries, which is a fair outcome given the fact that mandatory binding dispute resolution mostly benefits companies who are residents of those jurisdictions. Otherwise, G-24 countries could request a cap to the costs charged to developing countries, expressed as a percentage of GDP. 16 Arias, Isaac and Calderoni, Anarella.(7.9.2021)“Analyzing Mandatory Binding Arbitration and the MAP”. Available at https://www.ciat.org/ciatblog-analyzing-mandatory-binding-arbitration-and-the­map/?lang=en&utm_source=WebBlog&utm_medium=CartaAutor&utm_campaign=analisis-del-arbitraje-vinculante-obligatorio­y-del-pam&utm_content=Septiembre2021.(last accessed on 21.2.2022) See also 17 International Chamber of Commerce(ICC)(2018). Techniques for controlling time and costs in arbitration: Report from the ICC Commission on Arbitration. Available at https://iccwbo.org/content/uploads/sites/3/2018/03/icc-arbitration-commission­report-on-techniques-for-controlling-time-and-costs-in-arbitration-english-version.pdf(last accessed on 21.2.2022)