Article 25 of the Model Tax Convention of the Organisation for Economic Co-operation and Development on Income and on Capital (“OECD Model Tax Convention”) and Article 25 of the United Nations Model Double Taxation Convention between Developed and Developing Countries (“UN Model Tax Convention”) had counted solely on the Mutual Agreement Procedure (“MAPr”), a process of dialogue between the disputing parties, to settle the tax treaty dispute. The MAPr describes the talks between the tax authorities of two Double Tax Agreement (“DTA”) participants. The aforementioned Model Tax Conventions aim to resolve tax disputes between treaty parties by referring them to the MAPr. Thus, there was no legally binding instrument in the Model Tax Conventions to force the treaty parties to negotiate a solution to tax issues. In order to increase the efficacy of the MAPr mechanism, the OECD in 2008 and UN Tax Committee in 2011 included Article 25(5) provision for binding ad hoc arbitration to each of their Model Tax Conventions. Nonetheless, the OECD and UN Model Tax Conventions recognise the restricted role of arbitration in solving tax treaty issues. Unresolved problems are only subject to arbitration if the parties to a treaty are unable to achieve an agreement on those issues within a MAPr process within a certain time limit. As a result, arbitration is best seen as a continuation of the MAPr procedure rather than as a separate and alternative means of resolving international tax disputes.