4. MAP and domestic law
4.5. Relief from collections, interest, and penalties
Many countries have differing views on whether interest and penalties on an underlying income adjustment are covered by a convention. In the view of some countries, the scope of some tax conventions does not extend to cover interest or penalties. In such cases, the competent authority is sometimes prohibited from directly waiving or dealing with interest or penalties resulting from adjustments that are the subject of a request for competent authority assistance.