17 applicable to the case of the taxpayer in question. Because of this possibility, it seems necessary to request that parties to a Resolution Panel disclose any binding or influential judicial decisions before the panel is initiated. Otherwise, the resources spent in the dispute resolution mechanism may be wasted if one of the countries cannot agree to the MAP that adopts the decision. This disclosure also aids in the construction of a transparent dispute resolution mechanism that does not waste resources. Finally, if an international appeals mechanism is included, G-24 countries must ensure that the parties entitled to appeal and the circumstances for appeals are clearly defined in a way that balances the potential for each country to insist on a particular interpretation of the standards on the one hand with the costs and the time involved in participating in an international appeals mechanism on the other. Enforcement recommendations for G-24 countries ★ Clarify that countries are only bound by the Resolution Panel decision(or any panel decision, for that matter) if the taxpayer does not challenge the MAP that adopts the decision in either country. ★ Request that countries disclose any binding judicial decisions before a Resolution Panel is initiated. ★ Create rules for an international appeals mechanism that balances costs and opportunities to insist in a particular position. Capacity building The impending reality of mandatory binding dispute resolution in OECD and G20 countries must be acknowledged by G-24 members who are members of the BEPS Inclusive Framework. As the developed world starts to gain more experience, there will be increasing pressure to adopt mandatory binding dispute resolution as a minimum standard for all IF members21 regardless of their developmental stage. This means, in practice, that the elective mechanism and the withholding of the signature of the MLC may be temporary strategies to delay the implementation of the mechanism. The wisest strategy, then, is to take advantage of this time to prepare and build local capacity, starting with MAP. This, of course, is unnecessary for those G-24 members who are not members of the IF, have a limited treaty network, and have a long-term goal to remain that way. For G-24 countries that are in the IF, one of the obvious requests to make at the Inclusive Framework discussions is to create a capacity-building program for developing countries on both the MAP and on mandatory binding dispute resolution, that should include tax inspectors from other countries who have extensive experience in the negotiation of MAPs and arbitration. Both the UN and the South Center have training programs geared at improving developing country capacities in the MAP. The South Center program(still in its early stages) also provides South-to-South mentoring, so that G-24 21 See, for example, the replay of the public consultation meeting on the 2020 review of the Action 14 Minimum Standard, available at https://www.oecd.org/tax/beps/public-consultation-meeting-2020-review-beps-action-14.htm.(last accessed on 21.2.2022) Specifically, see the video at 2:20:40 and the following minutes.