The UAE Ministry of Finance has issued official guidance on the Mutual Agreement Procedure (MAP), outlining how businesses and individuals can seek relief from double taxation under the country’s international tax treaty network. The guidance was published to clarify eligibility, procedural steps, and documentation requirements for MAP claims.
Under the new framework, taxpayers must submit a MAP claim within three years from the date they become aware that double taxation may arise. This typically applies in cases involving cross-border transfer pricing adjustments or disputes over the existence of permanent establishments in more than one jurisdiction.
The MAP mechanism, included in many of the UAE’s double tax treaties, allows competent authorities of the contracting states to resolve disputes regarding taxation rights and eliminate instances of economic double taxation — where the same income is taxed by two jurisdictions.
The guidance also states that prior decisions by UAE courts or the Tax Dispute Resolution Committee may restrict the relief available under MAP. Taxpayers must provide a detailed list of supporting documents when submitting a claim.
The Ministry confirmed that MAP cases will be processed in line with OECD-recommended timelines, provided all required information is submitted promptly. Taxpayers are advised to ensure their case qualifies for MAP relief and determine the appropriate jurisdiction for filing their request.
This publication is part of the UAE’s broader effort to strengthen tax certainty, enhance transparency, and reduce cross-border tax disputes for multinational enterprises and international investors.
