With cross-border controversy growing at a rapid pace, companies need to be aware of options to resolve tax controversy disputes. The Mutual Agreement Procedure (MAP) is one avenue that companies may consider. OECD Base Erosion and Profit Shifting (BEPS) Action 14 efforts and the peer review process have helped drive improvements to MAP. These improvements have resulted in growing taxpayer participation in MAP, a number of countries introducing new MAP guidance (such as the Philippines and Morocco), increased resources devoted to MAP, and countries issuing updated MAP guidance. An example of such a development can be found in the EY...