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 access of MAP; (C) technical issues; and (D) implementation of the MAP process. The guidance follows the amendments made in May 2020 which contains the Income-tax (8th Amendment) Rules, 2020 to amend rule 44G of the Income-tax Rules, 1962 on MAP. The guidance is comprehensive and provides essential information for all taxpayers intending to apply for resolution under the MAP. It includes recommendations from OECD on the key areas of improvements in addition to the requirements under the BEPS Action 14 minimum standard in relation to an effective dispute resolution mechanism.
