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

Iceland

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

Developments relating to MAP in the tax treaty network

• DTC was concluded with Japan and came into force on January 1, 2019. DTC’s have also been signed with Australia in 2021 and Andorra in 2022. They have not been ratified by contracting states. Agreements have also been concluded with Saudi Arabia in 2022 and Brazil in June 2023. Both these agreements are waiting official signatures.

Other developments relating to MAP

• No developments were reported

Latest Action 14 Peer Review report

15 April 2021 - https://doi.org/10.1787/8b1deca3-en

Tax treaty network of Iceland

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

• status of MLI: in force.

Table 1. State of play of Iceland'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
42	5	3

Source: OECD

Iceland's MAP programme

Organisation of competent authority function

• one person:

  • one head of unit

  • one person working on MAP cases (that person works on other tasks as well):

    • the same person works on both attribution/allocation cases and other cases but can seek assistance from other units of the IRC if needed.

• contact persons for MAP requests:

  • Iceland Revenue and Customs

  • att. Elin Margret Thrainsdottir

  • Katrinartun 6

  • 105 Reykjavik

  • Iceland.

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	Gagnkvæmt samkomulag (MAP), October 2019	https://www.skatturinn.is/einstaklingar/skattskylda/tviskottunarsamningar/%23tab5 (Section “Hvernig skal óskað eftir gagnkvæmu samkomulagi?” to be referred to for form and content of a MAP request, including information requirements)
MAP profile	16 October 2019	https://www.oecd.org/tax/dispute/Iceland-Dispute-Resolution-Profile.pdf

Overview of Iceland's MAP Statistics for 2022

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

Figure 2. Cases closed in 2022

Source: OECD

Figure 3. Evolution of Iceland's MAP caseload (2016-22)

Source: OECD

Table 3. Overview of Iceland’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	1	0	0	1
Other cases	2	6	5	3
Total	3	6	5	4

Source: OECD

Table 4. Iceland’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	5	17.86	5	3.57	10	10.72
All cases	5	N/A	5	N/A	10	N/A

Source: OECD