Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

Sri Lanka

Recent developments relating to MAP in Sri Lanka prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• Sri Lanka did not provide the relevant information.

Other developments relating to MAP

• Sri Lanka did not provide the relevant information.

Latest Action 14 Peer Review report

Sri Lanka did not provide the relevant information.

Tax treaty network of Sri Lanka

• 44 treaties, applicable to 44 jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: not signed.

Table 1. State of play of Sri Lanka's tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
18	0	26

Source: OECD

Sri Lanka's MAP programme

Organisation of competent authority function

• three persons (all of whom also work on other tasks as well)

• contact persons for MAP requests:

  • Mr D. R. S. Hapuarachchi Deputy Commissioner General of Inland Revenue ( Tax Policy & International Tax Policy) Inland Revenue Department, Colombo 02, Sri Lanka, [e-mail] , [phone] & [phone]

  • or Mr N.M.M.Mifly Senior Commissioner of Inland Revenue ( Tax Policy & International Tax Policy) Inland Revenue Department, Colombo 02, Sri Lanka, [e-mail], [phone] & [phone]

  • or Ms S O A C R Niwunhella Commissioner of Inland Revenue (International Tax Policy) Inland Revenue Department, Colombo 02, Sri Lanka, [e-mail], [phone] & [phone].

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	Mutual Agreement Procedure (MAP) Guidelines, 2023	http://www.ird.gov.lk/en/publications/International/IRDSL_MAP_Guideline.pdf (Section 2.5 to be referred to for form and content of a MAP request, including information requirements)
MAP profile	10 March 2021	https://www.oecd.org/tax/dispute/sri-lanka-dispute-resolution-profile.pdf

Overview of Sri Lanka's MAP Statistics for 2022

Please refer to https://www.oecd.org/tax/dispute/map-statistics-sri-lanka.pdf for details with respect to Sri Lanka's MAP Statistics.

Cases closed in 2022

No MAP cases were closed by Sri Lanka in 2022.

Figure 2. Evolution of Sri Lanka's MAP caseload (2016-22)

Source: OECD

Table 3. Overview of Sri Lanka’s MAP caseload for 2022

Inventory for year 2022	Opening Inventory 1/1/2022	Cases started	Cases Closed	End Inventory 31/12/2022
Attribution/allocation cases	0	0	0	0
Other cases	2	0	0	2
Total	2	0	0	2

Source: OECD

Table 4. Sri Lanka’s average time to resolve MAP cases in 2022

Cases resolved in year 2022	Pre-2016 cases		Post-2015 cases		All
	Number of cases	Average time	Number of cases	Average time	Number of cases	Average time
				Start to End
Attribution / Allocation cases	0	N/A	0	N/A	0	N/A
Other cases	0	N/A	0	N/A	0	N/A
All cases	0	N/A	0	N/A	0	N/A

Source: OECD