18 Competent Authorities may about the issues discussed and the difficulties encountered when facing tax administrations with greater resources and more extensive experience. The Centro Interamericano de Administraciones Tributarias(Interamerican Tax Administration Center, or CIAT), on the other hand, is looking to establish a training program in tax dispute resolution, including mandatory binding mechanisms and a dispute resolution toolkit. Capacity building recommendations for G-24 countries ★ Request a specific capacity building program on mandatory binding dispute resolution for developing countries. ★ Train CAs in the MAP while the elective mechanism is still elective or if the country desires to expand its treaty network in the long term. Conclusions The tax certainty discussions happening at the BEPS Inclusive Framework point towards an advance in the trend to propose mandatory and binding solutions to international tax disputes, which stems from an increasing ambition to achieve uniformity in the substantive(and ever more complex) international tax standards approved in the framework of the BEPS Project. Ten of the G-24 member and observer countries have not joined the BEPS IF, while 23 are active members of the framework, therefore experiencing the increased pressure for enhanced international tax dispute resolution in spite of the mind-blowing complexity of the new rules. However, the difference now is that they have an opportunity to request the inclusion of design features that may contribute to building a system that takes into account the needs and circumstances of developing countries, regardless of whether they choose to join the MLC in the middle of 2022 or decide instead to pursue domestic measures to tax remote and digital businesses. As mentioned above, actively contributing to shaping the system does not imply a political compromise to join, as has been exemplified by the United States. Below is a list of some of the design contributions that the author believes may make the system more inclusive and even provide opportunities for G-24 countries to shape the system through reasoned decisions in ways that are not possible given the political constraints and consensus requirements at the IF: Cost-related strategies for G-24 countries ★ Propose virtual meetings and case accumulation for cost efficiency. ★ Propose common funding of total costs split proportionately to the GDP of participating jurisdictions in each mechanism. ★ Propose ceilings to the costs borne by developing countries expressed as a percentage of GDP. ★ Propose the creation of a developing country fund to be financed by developed countries and by a percentage of the amounts in discussion for each panel to be contributed by the levying country. ★ Take advantage of national legal defense agencies to use the resources to retain legal or accounting advice, or to bring an expert witness to the procedure.