Switzerland: Federal Council adopts dispatch on Federal Act on implementation of international tax agreements
On 4 November 2020, the Swiss Federal Council adopted the dispatch on the Federal Act on the implementation of international tax agreements. With this proposal, the Federal Council is adapting the existing law to the changes made to international
See MoreUS: IRS updates parameters for APA and MAP
On 28 October 2020, the US Internal Revenue Service (IRS) published that it is updating parameters that the Advance Pricing and Mutual Agreement program (APMA), a representative office of the U.S. competent authority, will follow in implementing
See MoreSouth Korea: NTS releases updated MAP guidance
On 20 October 2020, South Korea's National Tax Service (NTS) has released updated Mutual Agreement Procedure (MAP) guidance on the official website. The guidance prescribes the following key areas: Overview of a Mutual Agreement Procedure
See MoreAustria signs MAP agreement with Sweden
On 16 October 2020, the Finance Ministry of Austria announced that Austria signed an agreement regarding the implementation of agreements concluded on the basis of Article 22 (Mutual Agreement Procedure) with Sweden. The agreement effects from 6
See MoreColombia: DIAN issues resolution on Mutual Agreement Procedure
On 21 August 2020, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has issued Resolution No. 000085 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
See MoreIndonesia: Tax agency issues regulation on MAP process
On 11 August 2020, the Indonesian Directorate General of Taxation posted online Regulation No. PER-16/PJ/2020, on the mutual agreement procedure (MAP) rules under DTAs. The regulation covers: 1) the scope and definition of MAPs; 2) the deadline
See MoreIndia: CBDT publishes guidance on mutual agreement procedure (MAP)
On 7 August 2020, the Central Board of Direct Taxes (CBDT) has published new Mutual Agreement Procedure (MAP) Guidance. The Guidance comprises of four sections, including: (A) introduction and basic information; (B) access and denial of
See MoreUS and Switzerland sign competent authority arrangement on implementation of arbitration
On 28 July 2020, U.S. and Switzerland signed an agreement for the implementation of the arbitration process provided for in Article 25 (Mutual Agreement Procedure) of the 1996 income tax treaty between the two countries as amended by the 2009
See MoreNetherlands updates mutual agreement procedures
On 22 June 2020, the Ministry of Finance issued a decree updating the mutual agreement procedures (MAP). The decree is effective retroactively to 11 June 2020, and replaces a prior (2008) decree. The decree was updated to reflect recent
See MoreItaly introduces new dispute resolution mechanisms
On 10 June 2020, the Italian Government published Legislative Decree n. 49 enacting EU Directive No. 2017/1852 regarding tax dispute resolution mechanisms and in particular disputes arising from the interpretation and application of tax
See MoreSaudi Arabia: GAZT publishes guidance on MAP
On 9 June 2020, the General Authority of Zakat and Tax (GAZT) of Saudi Arabia has published MAP Guidance (Request for Mutual Agreement Procedure –Taxpayer guidance). The purpose of this document is to set out the process through which taxpayers
See MoreAustralia updates guidelines for resolving international tax disputes
The Australian Taxation Office (ATO) has updated the guidelines for the mutual agreement procedure (MAP) and arbitration arrangements. The updated guidelines reflect modifications made (or to be made) in some of Australia’s tax treaties made
See MoreUkraine: President signs law to implement BEPS and other provisions
On 21 May 2020, the President of Ukraine signed Law No. 466-IX (Draft Law No.1210) “On Amendments to the Tax Code of Ukraine on Improvement of Tax Administration, Elimination of Technical and Logical Inconsistencies in Tax Legislation", which was
See MoreIndia: CBDT amends rules for resolution of tax disputes under MAP
On 6 May 2020, the Indian Central Board of Direct Taxes issued Notification No. 23/2020, amending the 2020 income tax rules on mutual agreement procedures (MAPs) regarding dispute resolution. Under the revised rules, the authorities can now try
See MoreUS: IRS announces to change the procedures for filing MAP and APA
On 11 May 2020, IRS officials announced certain modifications to procedures for filing documents under Rev. Proc. 2015-40, 2015-35 IRB 236 (mutual agreement procedure (MAP) requests), and Rev. Proc. 2015-41, 2015-35 IRB 263 (advance pricing
See MoreSouth Africa: SARS publishes issue 3 of the guide regarding MAP
On 20 March 2020, the South African Revenue Service (SARS) released the third issue of the guide on the mutual agreement procedure (MAP) that allows competent authorities from the governments of contracting jurisdictions to interact with the intent
See MoreQatar introduces directives on MAP
On 11 February 2020, Qatar's General Tax Authority (GTA) has published following six directives on the application of the mutual agreement procedure (MAP) under double taxation avoidance agreements in relation to the implementation of base erosion
See MoreUkraine: Parliament approves draft law to implement BEPS provisions
On 16 January 2020, the Ukrainian Parliament approved draft laws on the improvement of the administration of taxes and elimination of certain inconsistencies in tax legislation (Law No 1209-1 and Law No 1210) to implement the Base Erosion and
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