Switzerland publishes guidance regarding mutual agreement procedure

June 25, 2018

The Swiss State Secretariat for International Financial Matters has released guidance for mutual agreement procedure (MAP) requests under Switzerland's tax treaties. Switzerland has concluded double taxation agreements with numerous countries.

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Belgium issues a FAQs on MAP and APA

June 18, 2018

On 23 May 2018, the Public Federal Service (SPF) of Belgium published a document of FAQ on Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) procedure. The assessee may also request that the tax due in Belgium is not invoiced

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Slovenia publishes the clarification on MAP procedure

June 01, 2018

The Ministry of Finance of the Republic of Slovenia published the clarification on the Mutual Agreement procedure (MAP) on 7 May 2018, which is set out in the MAP scheme of the Slovenian Tax Treaty Network. The clarification provides detail in the

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Canada: CRA issues MAP program report

April 15, 2018

The Canada Revenue Agency (CRA) issued the latest mutual agreement procedure (MAP) program report on April 13, 2018. The MAP program is a service provided by the CRA to assist taxpayers in resolving cases of double taxation or taxation not in

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Norway: Government publishes new guidance on MAP

February 19, 2018

The Norwegian Government published detailed taxpayer guidance on the mutual agreement procedure (MAP) framework set out in Norway’s tax treaties on 7th February 2018. It is an instrument which shall ensure that states apply the tax treaties

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Malaysia: IRBM amends the APA rules and updates the MAP guidelines

February 08, 2018

Recently, the MIRB (Malaysia Inland Revenue Board) has published an amendment to the APA Rules and the updated Mutual Agreement Procedure (“MAP”) Guidelines. The APA rules referred to as the Income Tax (Advance Pricing Arrangement) Rules 2012

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India clarifies position on acceptance of the MAP and bilateral APA

December 10, 2017

On 27 November 2017, the Indian Government has announced that the MAP for transfer pricing disputes and the bilateral advance pricing agreement (APA) process would be available to taxpayers even where Article 9(2) or the equivalent is not present in

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Japan publishes guidance for taxpayers on the MAPs

September 30, 2017

Recently, the National Tax Agency of Japan has released a guidance on mutual agreement procedures (MAP) on their website. This guidance has been prepared based on the recommendation 2.1 indicated in the final report on Action 14 (Making Dispute

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Luxembourg: Tax authority publishes circular on mutual agreement procedure

September 28, 2017

To set out the procedures for the implementation of the mutual agreement procedure (MAP), on 28 August 2017, the Director of Taxes published Circular L.G. Conv. D.I. No. 60. The MAP intends to eliminate legal and economic double taxation. The MAP

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Malta: Guidance on the use of MAP published

December 19, 2016

On 15 Dec 2016, The Commissioner for Revenue has published guidance issued under the provisions of article 96(2) of the Income Tax Act (ITA) on the use of Mutual Assistance Procedure

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