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

Azerbaijan

Recent developments relating to MAP in Azerbaijan prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• Azerbaijan is in the process of signing the MLI. The ratification process will ensue.

• Signature of the tax treaty with Japan on 27 December 2022.

• Signature of the tax treaty with Slovakia on 7 June 2023.

Other developments relating to MAP

• A draft MAP guidance is under works.

Latest Action 14 Peer Review report

Azerbaijan is yet to be peer reviewed under Action 14.

Tax treaty network of Azerbaijan

• 56 treaties, applicable to 54 jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: not signed.

Table 1. State of play of Azerbaijan'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
39	4	1

Source: OECD

Azerbaijan's MAP programme

Organisation of competent authority function

• four persons:

  • four persons working on MAP cases

    • two persons work on attribution/allocation cases and two persons work on other cases.

• contact persons for MAP requests:

  • for attribution / allocation cases: Orkhan Musayev,

    Head of the International taxation and tax monitoring department,

    State Tax Service under the Ministry of the Economy, [e-mail]

    Jeyhun Ismayilov,

    Deputy-head of the International taxation and tax monitoring department, State Tax Service under the Ministry of the Economy, [e-mail].

  • for other cases: Elkin Mammadov,

    Head of the International taxation division,

    State Tax Service under the Ministry of the Economy, [e-mail].

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	In draft stage
MAP profile	4 April 2023	https://www.oecd.org/tax/dispute/azerbaijan-dispute-resolution-profile.pdf

Overview of Azerbaijan's MAP Statistics for 2022

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

Cases closed in 2022

No MAP cases were closed by Azerbaijan in 2022.

Figure 2. Evolution of Azerbaijan's MAP caseload (2022)

Source: OECD

Table 3. Overview of Azerbaijan’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	1	0	1
Other cases	0	1	0	1
Total	0	2	0	2

Source: OECD

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

Cases resolved in year 2022	Pre-2022 cases		Post-2021 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