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  • 1-February-2023

    English

    OECD releases manual on the handling of multilateral mutual agreement procedures and advance pricing arrangements pursuant to tax certainty agenda

    In line with the Forum on Tax Administration's tax certainty agenda, the OECD has published a Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements, intended to be abbreviated as the MoMA.

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  • 1-February-2023

    English

    Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements - Enhancing Tax Certainty

    Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) offer greater tax certainty to both taxpayers and tax administrations where different parts of the same transaction or arrangement involving a multinational enterprise are covered by multiple bilateral tax treaties. However, most jurisdictions have limited experience in coordinating bilateral MAP and APA cases to offer multilateral certainty. In accordance with its commitment to advancing the tax certainty agenda, the FTA MAP Forum, in conjunction with the FTA Large Business International Programme, has developed the Manual on the handling of Multilateral MAPs and APAs (MoMA) which is intended as a guide to multilateral MAP and APA processes from both a legal and procedural perspective. The MoMA provides tax administrations and taxpayers with basic information on the operation of such procedures and suggests different approaches based on the existing practices of jurisdictions, without imposing a set of binding rules. The MoMA allows tax administrations to explore whether implementation of these procedures is appropriate considering the circumstances of their own MAP and APA programmes and to consider whether the guidance therein may be incorporated in their domestic guidance on MAP or APA processes to provide additional clarity.

  • 24-janvier-2023

    Français

    Résolution des différends en matière de fiscalité internationale : l'OCDE publie de nouveaux documents clés

    Le Cadre inclusif sur le BEPS a convenu d'une nouvelle Méthodologie d'évaluation pour poursuivre le processus d’examen par les pairs de l'Action 14, des points de données supplémentaires dans les statistiques sur la Procédure amiable (PA), et de la création d'un nouveau cadre de suivi annuel pour rapporter les statistiques sur les Accords préalables en matière de prix de transfert (APP).

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  • 22-November-2022

    English

    2021 Mutual Agreement Procedure Awards

    On the occasion of Tax Certainty Day 2022, where a full range of tax certainty tools were discussed, the OECD released the 2021 MAP statistics and the winners of the 2021 MAP awards.

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  • 22-November-2022

    English

    OECD releases new mutual agreement procedure statistics and country awards on the resolution of international tax disputes

    The OECD releases today the latest mutual agreement procedure (MAP) statistics covering 127 jurisdictions and practically all MAP cases worldwide. These statistics form part of the BEPS Action 14 Minimum Standard and the wider G20/OECD tax certainty agenda to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms.

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  • 13-September-2022

    English

    Making Dispute Resolution More Effective – MAP Peer Review Report, Kazakhstan (Stage 2) - Inclusive Framework on BEPS: Action 14

    Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by Kazakhstan.

  • 13-September-2022

    English

    Making Dispute Resolution More Effective – MAP Peer Review Report, Thailand (Stage 2) - Inclusive Framework on BEPS: Action 14

    Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by Thailand.

  • 13-September-2022

    English

    Making Dispute Resolution More Effective – MAP Peer Review Report, Gibraltar (Stage 2) - Inclusive Framework on BEPS: Action 14

    Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by Gibraltar.

  • 13-September-2022

    English

    Making Dispute Resolution More Effective – MAP Peer Review Report, Aruba (Stage 2) - Inclusive Framework on BEPS: Action 14

    Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by Aruba.

  • 13-September-2022

    English

    Making Dispute Resolution More Effective – MAP Peer Review Report, The United Arab Emirates (Stage 2) - Inclusive Framework on BEPS: Action 14

    Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by the United Arab Emirates.
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