Transfer pricing

3 How MAP - 3.7. Debriefing the taxpayers

 

 
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3 How MAP works

3.7. Debriefing the taxpayers

Although competent authority proceedings are a government-to-government process and taxpayers do not have a specific right to attend or observe discussions between the competent authorities, the competent authorities recognize that the taxpayer is a stakeholder and client in the MAP process.

As such, it is appropriate to debrief the taxpayer after each substantial MAP discussion (usually via telephone) and at the conclusion of a file.  The debriefing need not be a detailed summary of the meeting nor should it be a full disclosure.  The debriefing should give the taxpayer a general sense of the direction of its case and some estimation, if possible, of the time to resolve it.

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