Amendment In Mutual Agreements Procedure (MAP) Rules - A Taxpayer's Tool Reinvented

INTRODUCTION

Mutual Agreements Procedure (MAP) is a model or mechanism available to taxpayers to resolve disputes that have arisen due to double taxation. When two countries enter into an agreement to avoid double taxation, it gives a clear pathway to the concerned authorities under MAP in those particular jurisdictions. Article 25 of the OECD Model Convention for the Avoidance of Double Taxation talks about assistance of Competent Authorities under MAP.

The foremost benefit of MAP is avoidance of double taxation. It is very rare that a case under MAP is not resolved. Study report states that many tax-related disputes have been resolved between April, 2014 and December, 2018 with the MAP. The MAP resolution, once accepted, eliminates the need for unnecessary litigation.