One of the key messages that emerged from the OECD's December 2003 public consultation on improving the process for resolving tax treaty disputes was the need to improve the transparency of the mutual agreement procedure (MAP) process. As a first step in improving transparency, the OECD decided to make available to the public, via its website, “Country Profiles on Mutual Agreement Procedures” of all OECD member countries, which contain information about the Competent Authorities’ contact details, domestic guidelines for MAP and other useful information for both tax authorities and taxpayers.
The contents of the profiles are as follows:
- Competent Authority contact information;
- Organisation of the Competent Authority (i.e. allocation of subject matter responsibility);
- The scope of the MAP & MAP Advance Pricing Arrangements (APAs);
- References to domestic guidelines and administrative arrangements;
- The time for filing a MAP request;
- The form of a MAP request;
- Documentation requirements for a MAP request;
- User fees (if any);
- Relevant provisions on tax collection, penalties and interest pending the outcome of the MAP process;
- Other dispute resolution mechanisms; and
- Links to websites of the government revenue department.
Below are Country Profiles on Mutual Agreement Procedures for OECD member countries (click on the country name for a link to its profile).
The OECD also seeks to make available similar information for non-OECD economies and encourages them to provide their profiles to the Secretariat. Currently available country profiles of non-OECD economies (NOEs) are shown below.
Every effort has been made to ensure the information is accurate but if you do find errors or omissions please email us at: email@example.com
2004 Discussion Draft: Proposals for Improving Mechanisms for the Resolution of Tax Treaty Disputes