Malta’s Commissioner for Revenue has issued the updated guidelines on  Mutual Agreement Procedure (MAP) Guidelines on 11 March 2025.
These guidelines explain how the MAP functions, allowing Malta’s Competent Authority to collaborate with counterparts from other nations to resolve tax-related disputes under bilateral tax treaties and the EU Arbitration Convention. The MAP is designed to address challenges like double taxation and discrepancies in treaty interpretation.
The guidelines offer detailed insights into the MAP process, including the role of Malta’s Competent Authority and the procedure for taxpayers to request MAP assistance. They outline the minimum information required for a request, the factors considered when deciding whether to accept or decline a request and the rights of taxpayers to appeal decisions.
The guidelines also cover the tax suspension process, the handling of interest during a MAP, and limitations on how exchanged taxpayer information can be used.
The MAP serves as an additional dispute resolution mechanism alongside the options available under domestic law. Taxpayers can seek MAP assistance regardless of the remedies provided by national regulations.
