Taiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP
On 24 June 2021, the Ministry of Finance issued a Decree which stipulates that when tax collection authorities negotiate cross-border bilateral or multilateral advance pricing arrangements (APAs) (hereinafter referred to as "BAPAs") with the
See MoreMorocco publishes guidance on mutual agreement procedure
The Ministry of Finance (MoF) of Morocco has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve double taxation, typically
See MoreSpain publishes a decree amending Mutual Agreement Procedure (MAP)
On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. The decree implements three packages of initiatives to enhance
See MoreUAE publishes guidance on mutual agreement procedure
The Ministry of Finance (MoF) of the United Arab Emirates (UAE) has published guidance on the mutual agreement procedure (MAP), which provides a dispute resolution procedure to resolve tax treaty related disputes. MAP is designed to relieve
See MoreMalta enacts Budget Measures Implementation Act 2021
On 16 April 2021, Malta has published and enacted Act to implement Budget Measures for the Financial Year 2021and other administrative measures (Act No. XVIII of 2021). The budget measures were announced in October 2020 which came into force on
See MoreOECD: Peer review reports under BEPS Action 14
On 15 April 2021 the OECD released peer review assessments under Action 14 of the project on base erosion and profit shifting (BEPS) which aims to make dispute resolution mechanisms more effective. These stage two monitoring reports relate to
See MoreLuxembourg: Tax Authorities issues circular on updated MAP guidance
On 11 March 2021, the Luxembourg Tax Authorities has issued Circular L.G. - Conv. D.I. n° 60 regarding the updated mutual agreement procedure (MAP) guidance. The Circular replaces previous Circular L.G. Conv. D.I. No. 60 of 28 August 2017. The
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreItaly: New regulations for mutual agreement procedure
On 16 December 2020, the Italian tax authority published regulations to implement new tax dispute resolution mechanisms and mutual agreement procedure (MAP). The Measures to allow taxpayers to contact the tax authorities in Italy to discuss the
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US and Mexico renew competent authority agreement on Maquiladoras
On 16 November 2020, the Internal Revenue Service (IRS) announced that IRS and Mexico’s Servicio de Administración Tributaria (“SAT”) have agreed to renew the Qualified Maquiladora Approach Agreement (“QMA”), a coordination
See MoreSwitzerland: 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
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