Netherlands 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
See MoreIreland: Revenue updates MAP guidance for BEPS MLI
The Revenue has recently released eBrief No. 223/19 entitled Tax and Duty Manual Part 35-02-08 on amended MAP guidelines to implement for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS
See MoreDTA between Ecuador and Japan enters into force
On 28 December 2019, the Double Taxation Agreement (DTA) between Ecuador and Japan was entered into force and applies from 1 January 2020. The DTA contains Dividends rate 5%, Interest rate 10%, and Royalties rate
See MoreGermany gazettes a law implementing EU directive on tax dispute resolution mechanism
On 12 December 2019, the German Official Gazette published a law implementing EU directive on tax dispute resolution providing a uniform mechanism to address tax treaty disputes among EU member states that meets the BEPS Action 14 minimum
See MoreOECD: Input requested for dispute resolution peer reviews
On 18 November 2019 the OECD invited interested parties to submit input in relation to the tenth batch of dispute resolution peer reviews. Information should be submitted to the OECD by 16 December 2019 using the taxpayer input questionnaire. The
See MorePoland publishes a law implementing EU directive on dispute resolution and new provisions on APAs
On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019. The law
See MoreTurkey: Revenue Administration issues guideline on MAP
On 17 October 2019, the Turkish Revenue Administration has released guideline on the mutual agreement procedure (MAP) under double taxation agreement on their website as well as a table of guidance indicating the time limits for each country
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
See MoreColombia: DIAN issues resolution on MAP
On 13 August 2019, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has published Resolution No. 000053 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
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