Transfer pricing

3 How MAP - 3.7. Debriefing the taxpayers - 3.7.1

 

 
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3 How MAP works

3.7. Debriefing the taxpayers

3.7.1.Transparency at the resolution stage

Transparency is one issue where competent authorities in general can improve.  It becomes even more important at the resolution stage of the MAP to dispel allegations that competent authorities have traded cases.  Thus, advising the taxpayer not only of the outcome but how the competent authorities arrived at the decision is important.

Best Practice Nº17:   Decision summaries

A summary of a MAP decision provided to the taxpayer, which describe the underlying reasons and principles of an outcome, will assist in examining why a particular result was agreed to.

These summaries can be either via closing letter to a case or provided orally in a closing meeting.  Meetings would be beneficial in contentious cases or cases with unusual outcomes to ensure all elements of the decision are understood. 

 

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