NTS publishes 2025 MAP guidance outlining eligibility, three-year filing window, OECD-based proceedings, documentation, implementation timelines, and standardised forms for resolving international tax disputes.
Korea (Rep.)’s National Tax Service (NTS) on 18 December 2025 published online the 2025 Guidelines for Requesting Mutual Agreement Procedure (MAP) Assistance, providing a comprehensive framework for resolving international tax disputes with treaty partners.
The guidance explains how taxpayers can seek relief from double taxation or inconsistent treaty interpretations through formal consultations between competent authorities.
Key topics covered include eligibility and conditions for MAP applicants, a limited filing period of three years from the date the applicant becomes aware of the relevant assessment, proceedings and closing of MAP under the OECD Model Tax Convention, and the documentation required to initiate a case.
The guidelines also detail the implementation of MAP outcomes, including the determination of a one-year implementation period, and provide standardised forms for applicants to ensure compliance with administrative protocols.
The guidance clarifies the legal relationship between MAP and domestic judicial remedies, noting that tax collection may be deferred while a case is active. Recent statistical data illustrate case volumes and average resolution times, with transfer pricing continuing to be the primary issue in disputes.
The NTS said the guidelines aim to streamline international dispute resolution, enhance consistency in treaty application, and provide clear procedural steps for taxpayers engaging with the MAP process.
