Definition of mutual agreement procedure

A mutual agreement procedure (MAP) is a feature in many double taxation treaties. A MAP allows a taxpayer which considers that it is being taxed in a way that is not in accordance with the terms of the treaty, as a result of the actions of one (or both) of the relevant tax authorities, to present its case to the tax authority in the country in which it is resident.

The tax authority has the power to consider the issue, and give relief to resolve the matter, without a requirement to contact the other tax authority. If the case cannot be resolved in this way, both states can consult to try to resolve the case by mutual agreement. Note that a MAP does not guarantee the elimination of any double taxation, rather it endeavours to do so. [1]

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