Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
See MoreGeorgia adopts rules on Mutual Agreement Procedures (MAP)
The Ministry of Finance of Georgia recently published Decree No. 258 of July 2023, which approves the rules for the Mutual Agreement Procedures (MAP) under the Tax Treaties of Georgia or the provisions of the BEPS MLI. The rules encompass various
See MoreNigeria: FIRS releases new guidelines on mutual agreement procedures
On 23 May 2023, the Federal Inland Revenue Service (FIRS) of Nigeria has released Information Circular No. 2023/04 which includes new Guidelines on Mutual Agreement Procedure (MAP). The purpose of the guidelines is to provide guidance on how to
See MoreSri Lanka: IRD publishes MAP guidelines
On 8 May 2023, the Sri Lanka Inland Revenue Department (IRD) has published Mutual Agreement Procedure (MAP) guidelines. The guidelines provide several key aspects related to Mutual Agreement Procedure (MAP) requests in Sri Lanka. The guidelines
See MoreChile: Tax authority clarifies time limits for MAP requests
On 19 April 2023, Circular No. 19 was released by the Chilean tax authority. This circular modifies Circular No. 13, which was published on 18 March 2022, which provides guidance on the Mutual Agreement Procedures (MAP) under Chile’s tax treaties.
See MoreLuxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
See MoreChile launches public consultation on MAP
The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public
See MoreMalaysia: IRBM issues FAQs to clarify MAP guidelines
On 1 February 2023, the Inland Revenue Board of Malaysia (IRBM) has issued a list of frequently asked questions (FAQs) on the mutual agreement procedure (MAP) to provide further clarification to the 2017 MAP guidelines. In relation to the
See MoreDominican Republic: DGII Publishes general standard rule on MAP
On 30 August 2022, the Dominican Tax Authorities (DGII) issued a new general standard rule on Mutual Agreement Procedures (MAP) for Dispute Resolution under the country's tax treaties. The general rules introduced details for submitting MAP
See MorePhilippines issues MAP Guidelines
The Philippines Bureau of Internal Revenue (BIR) has published Revenue Regulations No. 10/2022 on mutual agreement procedure (MAP) guidelines and process for requesting MAP assistance. The MAP article in the Double Taxation Agreements or tax
See MoreSouth Korea: NTS updates MAP guidance
On 30 June 2022, South Korea’s National Tax Service (NTS) has issued updated Mutual Agreement Procedure (MAP) guidance on the official website. The guidance prescribes the following key areas: Overview of MAP; Application of MAP;
See MoreIndia: CBDT updates guidance on MAP
On 10 June 2022, India's Central Board of Direct Taxes (CBDT) issued comprehensive updated guidance on the Mutual Agreement Procedure (MAP) and related matters. The guidance supplements the previous guidance published on 7 August 2020 and addresses
See MoreDominican Republic: DGII invites comments on the draft MAP rule
On 26 May 2022, the Dominican Republic's Directorate General of Internal Revenue (DGII) launched a public consultation on a draft general standard (rules) on Mutual Agreement Procedures (MAP) for dispute resolution under the country's tax treaties.
See MoreAustria publishes guidance on MAP procedures under DTAs, MLI, and EU Laws
On 6 May 2022, the Ministry of Finance issued new guidelines on mutual agreement and arbitration procedures (MAP) under the Austrian double taxation agreements, the EU Arbitration Convention, the BEPS Multilateral Instrument (MLI), and the EU Tax
See MoreUK: Transfer Pricing and Diverted Profits Tax Statistics
On 28 April 2022 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2020/21 tax year. HMRC is anxious to reduce the amount of the tax gap,
See MoreOECD: Peer Review Reports on Making Tax Dispute Resolution More Effective
On 14 April 2022 the OECD published a further set of peer review reports under BEPS Action 14 which is concerned with making tax dispute resolution mechanisms more effective. These reports set out the results of assessments under stage two of the
See MoreOECD: Second Stage Peer Review of Guernsey under BEPS Action 14
On 24 January 2022 the OECD issued the stage 2 peer review report assessing Guernsey’s compliance with the minimum standard under Action 14 of the project on base erosion and profit shifting (BEPS). Action 14 is concerned with making tax dispute
See MoreIreland: Revenue updates guidelines for requesting MAP assistance
On 23 December 2021, the Revenue published an eBrief No. 236/21 on the updated Manual for requesting Mutual Agreement Procedure (“MAP”) assistance in Ireland. The Guide has been updated to incorporate Council Directive (EU) 2017/1852 of 10
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