id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-401	Ault, Hugh J.	Improving the Resolution of International Tax Disputes	2022	15	.pdf	application/pdf	5944	291	54	In addition, some countries take the position that they will not accept MAP cases on particular issues. In addition, under Article 25, paragraph 3, the competent authorities can on their own initiative consult together on issues of application and interpretation not directly brought up by taxpayer in a particular case and can also deal with double taxation generally even if not covered by treaty, though most MAP cases are taxpayer-initiated.	cache/ftr-401.pdf	txt/ftr-401.txt