Transfer pricing

6 Other MAP programs - 6.1 Accelerated Competent Authority Procedure (CAP)

 

 
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6. Other MAP programs

6.1. Accelerated Competent Authority Procedure (ACAP)

In addition to a request for competent authority assistance in respect of a specific adjustment to income, some competent authorities allow taxpayers to request assistance for subsequent filed taxation years on the same issue. Once an ACAP request has been received, a competent authority may consult with the appropriate authorities within the tax administration (audit function or field office) to determine whether an ACAP is suitable for the taxpayer’s particular circumstances. Normally, the issue must be one that is recurring and relevant to a specific adjustment.  

The competent authority then consults with the foreign competent authority under the MAP process endeavouring to resolve the issue.  In most cases, the request or acceptance of an ACAP will not preclude or diminish a tax administration’s right to later examine or review the issues addressed by the ACAP.

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