Taxpayers` rights are of the utmost importance in the context of fundamental changes in the regulation of international tax relations, which are determined by the need to combat global tax evasion. These changes create a high degree of uncertainty among taxpayers who, due to the decline in investment and entrepreneurial activities, could have a negative impact on the economic development of developing countries in particular. Therefore, modern states should offer a high degree of effectiveness in dispute resolution mechanisms, including the Mutual Agreement Procedure (POP). This is the procedural mechanism for taxpayers not to resolve their tax cases in accordance with the provisions of the double taxation agreements, by launching communication between the competent authorities of the contracting states that have entered into double taxation agreements. On the basis of the analysis of the pros and cons of POPs, it could be seen that their attractiveness to taxpayers is not as obvious, as some safeguards, such as the right to confidentiality or the right to be informed of the negotiation process between the competent authorities, are not obvious. In this context, the success of the international community is only partial, as it is difficult to find a common denominator and differences of interest at the global level. At the same time, the EU example shows that regional cooperation could be essential to improving taxpayers` rights under the POP, which could be taken into account by the BRICS in their attempts to improve tax dispute settlement mechanisms. Within the EU, the EU Arbitration Convention came into force on 1 January 1995 as an instrument that promised to allow the elimination of double taxation between Member States. It is important that it provides for a binding and binding arbitration mechanism that eliminates double taxation, with the advice of an independent advisory body, if the competent authorities fail to reach an agreement after two years. This went beyond the existing bilateral agreements at the time, which simply required the competent authorities to make their “best efforts” to eliminate double taxation. As Lombardo explains, the Mutual Agreement (MAP) procedure must be interpreted as “a particular procedure outside domestic law, which aims to represent the dispute on an amicable basis.” Overall, it is clear that the IML extends the access of the subject to three years, both in terms of the lengthening of the period during which the subjects must initiate a period of POPs, and an effective two-year period for the competent authorities to request a solution to the case (after that date, this may be subject to arbitration). The MLI has led to a greater homogeneity of approach on key issues such as arbitration and, above all, the adoption of a single map article for covered tax treaties. (3) The subject should be fully informed during the proceedings; Heidari, P.
(2017). Contradictory principle in the administrative court, with an emphasis on the administrative tribunal procedure. Journal of Social Sciences and Humanities of Shiraz University, 7(2), 83-116. (8) The implementation of a mutual agreement between the competent authorities should normally be conditional on the acceptance of such an arrangement by the subject and the withdrawal of the appeal of the subjects under the Law on the points covered by the mutual agreement (paragraph 2).