The Southern Consultations In Windhoek Namibia 2023

The conversation then drifted on questions on how to handle disputes in the absence of tax treaties. For developing countries, the answer was simple … “No treaty, no dispute-resolution mechanism.” For them, the Protocol should not create new legal bases.
But across the room, private sector voices insisted that disputes do not wait for treaties; businesses struggle with uncertainty, and governments lose revenue. They pressed for innovations, with some calling for strengthening MAP, others calling for coordinated unilateral Advance Pricing Agreements (APAs), and others for the view that temporary unilateral relief would prevent double taxation.