Each individual tax treaty has its own deadlines for applying for a MAP. The period is generally three years from the first notification of the measure leading to non-contractual taxation. Please note that for some tax treaties, the time limit is only two years, while other tax treaties do not have a time limit. It is therefore important that you look at the relevant tax treaty with respect to time limits. You can find more detailed information on our Double Taxation Exemption/Mutual Agreement Procedure page. Under the international tax system, the Alaw-free Procedure (MAP) – in Australia`s tax treaties – supports a resilient global economy and facilitates economic growth. MAP can help you: you will not receive an extension for the payment of underpaid Norwegian taxes if a case is handled in accordance with the rules of the procedure after agreement. Underpaid tax must be paid within the time you received. If you need to submit a case, please send your contact information to: Our double taxation treaties contain a provision called a friendly procedure. In this way, a taxpayer can submit his application for exemption from surplus tax to the competent authority of a tax administration. The procedure is also referred to as a request for assistance from the competent authority. In most cases where the assistance of the competent authorities is required, these are transfer pricing adjustments.
A MAGP can be invoked by taxpayers so that one country, in agreement with the other country, can eliminate cases of double taxation resulting from the actions of the tax administration of the other country. An ameprocious procedure is a process in which the authorities of two countries can agree, at your request, on how to avoid taxation that does not comply with the tax treaty. We need to agree with the authorities of the other country on what good taxation is. Some cases can be resolved without the participation of the authorities of the other country. Contact one of the authors to discuss the possibility of applying for THE MAP in your country, or to discuss your strategy for cross-border tax controversies in general. Map is also used in many countries as a basis for initiating bilateral advanced price (AA) agreements. In this approach, taxpayers take proactive steps to obtain the transfer pricing agreement between two countries that they apply to their cross-border transactions. In this context, a MAP is used as an instrument to avoid transfer pricing disputes. In addition to these developments, the European Union has proposed a new directive on double taxation dispute resolution mechanisms in the European Union, which aims to resolve cases of double taxation within the EU by agreement between member states. This could become another tool that EU taxpayers can access in due course.  The MAGP may be used by a taxpayer to determine which country is entitled to tax the taxpayer as a country of residence […].