Transfer pricing

6 Other MAP programs - 6.3. Other types of MAP proceedings

 

 
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6. Other MAP programs

6.3. Other types of MAP proceedings

Although not typical, a competent authority may, in rare cases, initiate competent authority proceedings and subsequent discussions without a specific request from a taxpayer in any situation where there is taxation not in accordance with a tax convention in order to protect domestic interests.

For example, a competent authority may disagree with the interpretation by its treaty partner of a provision in a tax convention.  Such a situation could involve a specific taxpayer or a group of taxpayers. In either case and if warranted and practicable, taxpayers should be advised of the competent authority proceedings and could be invited to make representations, if applicable, and they should in any event be advised of the outcome.

Other MAP proceedings initiated without a taxpayer, where competent authorities seek to clarify with their treaty partner their interpretation or application of a convention, as described in Subsection 1.2.2 Interpretation or application cases and double taxation in cases not otherwise provided for in a convention, are more common. 

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