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3.4.2.Other Issues According to Tax Model Agreements
The OECD and UN Model commentaries include similar provisions regarding other issues.…
The Committee generally recommends the following regarding the mutual agreement…
a)Minimal formalities should be required for initiating and conducting the mutual…
b)Cases within the mutual agreement procedure should be addressed individually, without…
c)Competent authorities should establish guidelines, principles, procedures, and…
Some states believe that the mutual agreement procedure should only be initiated…
If an agreement is not reached through the mutual agreement procedure or even if…
Paragraph 3 of Article 25 of the OECD Model grants certain powers to competent authorities…
According to the relevant provision, competent authorities can:…
•Clarify or complete terms if a term in the agreement is missing or misdefined.…
•Resolve issues arising from changes in the domestic legislation of one of the Contracting…
•Determine whether items treated as dividends under the thin capitalization rules…
•Engage in multilateral advance pricing agreements and bilateral pricing agreements…
•Establish appropriate procedures and conditions for involving a third state in cases…
An important point regarding the mutual agreement procedure is its alignment with…
The MAP is not a judicial procedure by nature. It facilitates tax authorities in…
3.4.1.In General
3.4.3.International Statistics on the Mutual Agreement Procedure
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