The Arbitration Convention of the European Union (EU) establishes a procedure for settling transfer pricing disputes for EU member states. This procedure may apply in cases of double taxation between companies in different EU Member States. Before applying for a MAP, the individual or company should speak with the appropriate authorities to determine if the problem can be resolved as part of the mutual agreement procedure. The tax administration advises and advises on the choice of the appropriate procedure. The Mutual Agreement Procedure (MAP) is a procedure negotiated between the competent authorities of the contracting states of a tax treaty. The aim is to resolve differences in interpretation and eliminate double taxation. The procedure of mutual unification may apply in situations where double taxation must be abolished. Double taxation means that a person`s or a company`s income has been taxed by the tax authorities of their country of residence and by the tax authorities of another country. In August 2020, the Central Council for Direct Taxes (CBDT) issued guidelines for the Mutual Agreement Procedure (MAP) which contain the following four parts: For more information on the submission of a POP application and the exceptions for individuals, see Chapter 3.4 of the tax administration guidelines on the mutual agreement procedure in the event of an international tax dispute. The map article of the Indian Income Tax Convention is based on Article 25 of the OECD Model Tax Convention.

An application for a POPs may be made by a taxpayer if it takes into account the actions of the tax authorities of one or both contractors or results in a tax that does not comply with the applicable tax treaty. Through this procedure, the competent authorities of the contracting states may settle disputes or difficulties in the interpretation or application of tax treaties on a consensual basis . . . . The Council`s European Directive on Mechanisms for the Settlement of Tax Disputes in the European Union provides a means of resolving cross-border tax disputes. This decision takes effect in Ireland by S.I. No.

306/2019. The regulation applies to litigation arising from future tax years as of January 1, 2018. Результатов : 42. Точных совпадений : 42. 80 The IRAS recognizes the importance of tax security in the rapidly changing business environment and is committed to assisting taxpayers in the consistent and accurate resolution of the principles of tax litigation and in accordance with recognized international tax rules and principles. When a Singapore tax subject is subject to double taxation as a result of adjustments made either by the IRAS or by a foreign certification body to transfer prices for its transactions with related parties, it may apply to the IRAS to resolve the double taxation through a MAP.