16 authority’s participation in future panels and even in specific bilateral or multilateral transfer pricing MAP procedures. Having a transparent procedure and outcome facilitates training and capacity building, which are always at the core of G-24 countries’ interests. It is important to note that if no publication is provided, the independent members may sell their insights to taxpayers and countries that can afford their services, which may widen the knowledge gap between developing and developed countries. The publications concerned should at least include versions in Spanish and French as official languages of the Inclusive Framework. Publication is already provided for in the MLI Sample Arbitration Agreement at paragraph 6, as is clear from par. 32 of the Commentary to the Sample Arbitration Agreement. Of course, publication should be made in a redacted form in order to protect the identity of the taxpayer and any other sensitive commercial or industrial information. The decision to publish the panel outcome not only brings further transparency to the process, but also facilitates training and learning by tax administrations that have not had extensive MAP experience. Transparency recommendations for G-24 countries ★ Request the publication of redacted briefs for each panel decision including the facts, competing proposals, issues or principles involved, and the reason for choosing one or the other proposal. ★ Taxpayers must be given access to procedural information and should be allowed to request the redaction of specific information that may be sensitive from a business point of view. Enforcement, annulment, and interaction with domestic remedies Enforceability and domestic annulment of mandatory binding dispute resolution decisions constitute an area that G-24 countries must explore in depth, especially when constitutional rights may create a variety of scenarios in each country once a decision has been published and adopted by CAs via the MAP. The enforcement of MAP decisions is different in each G-24 country, and the only commonality is that all countries that have gone through an Action 14 Peer Review must have legal faculties to implement MAP decisions regardless of domestic time constraints. In some countries, including the United States, the taxpayer has a right to challenge any MAP decision in domestic courts as part of their constitutional right to access courts. In these cases, the decision will no longer be binding upon the countries that signed the MAP, but the resources spent in the Resolution Panel will be at least partially wasted. Naturally, a domestic judicial decision issued in a foreign country is not likely to be enforced in G-24 countries, so in these situations developing countries should be free to enforce the original adjustment issued by their tax authorities even after a diverging decision had been reached. For this reason, it is recommended to clarify that the Resolution Decision is only binding if the taxpayer does not challenge it domestically in either country. Furthermore, countries may be bound by prior judicial decisions that can prevent them from agreeing to a MAP that provides a solution that deviates from the said precedent. This is especially important in the cases where a decision has been made in respect of other taxpayers that may create a precedent