13 This disclosure obligation facilitates the identification of conflicts of interest and allows for greater transparency for the entire mechanism. In all cases, G-24 countries will be encouraged to adopt strong criteria for standards of impartiality and independence of every expert with respect to any given taxpayer to exclude biased decision makers from the panels, especially since not all countries that have an interest in the dispute will be represented in the prevention panels. It is certainly useful to start putting together a several lists of experts/panel members who either come from G-24/developing countries or else show a deep understanding of low- and middle-income country positions, in order to facilitate adequate representation of developing country positions in the prevention and resolution panels. Panel Composition recommendations for G-24 countries ★ Propose sole participation of CAs for the Review Panel. ★ Propose an intermediate independent CA stage where CAs from similar countries are called to see if a solution may be jointly proposed by them. This stage would operate before independent experts are brought in, but only if both CAs consider that a set of independent CAs may reach an agreement. ★ Accept independent members in the Review and Resolution Panel, as long as they comply with strict disclosure and conflict of interest rules. ★ Promote diversity in independent panel members by limiting non-CA panel members to a maximum of one panel per fiscal year and prevent the same panel member from sitting in a procedure involving the same taxpayer in a period of five years. ★ Put together lists of experts/panel members that either come from G-24/developing countries or fully understand their views. Baseball vs. Independent Opinion Final offer or“baseball” arbitration was invented in the United States for sports cases and is still used by the Court of Arbitration for Sport(CAS) in the case of international anti-doping disputes, inspired by the need to have a rapid determination in the framework of a live sports competition. The original purpose of its adoption in tax matters, beyond the agility of the procedure, is closely related to the reluctance of states to renounce sovereignty in tax matters. On the one hand, it serves as a strong incentive for countries to agree in the MAP, thereby preserving sovereignty in the hands of the competent authorities. This fact has been verified in Europe, where the lack of arbitration cases in spite of the presence of the European Arbitration Convention shows that the“all or nothing” approach is effective in promoting negotiation and preventing extreme audit positions. On the other hand, even when the dispute advances into arbitration, the fact that the arbitrator cannot deviate from the competent authority proposals implies that there is substantial control by the CAs on the outcome of arbitration. These advantages are accompanied by reduced resolution times and reduced costs, as well as a system that is farther removed from the investment arbitration system that has raised significant concerns in the developing world.