Prix de transfert
Annex 2 - Best Practices
 |
|||||||
|
|||||||
Annex 2 - Best practices
| Best Practice N°1: | Resolving and publishing issues of interpretation or application | |
| Best Practice N°1: | Robust use of Article 25(3) power to relieve double taxation | |
| Best Practice Nº1: | Principled approach to resolution of cases | |
| Best Practice Nº3: | Transparency and simplicity of procedures for accessing and using the MAP | |
| Best Practice Nº4: | Providing complete, accurate, and timely information to the competent authorities | |
| Best Practice Nº5: | Allowing electronic submissions | |
| Best Practice Nº5: | Allowing early resolution of cases | |
| Best Practice Nº6: | Earlier notification of a potential case | |
| Best Practice Nº7: | Liberal interpretation of time limits and advising of treaty rights | |
| Best Practice Nº8: | Avoiding exclusion from MAP relief due to late adjustments or late notification | |
| Best Practice Nº10: | Consideration of MAP assistance for cases described as “tax avoidance" | |
| Best Practice Nº10: | Countries eliminate or minimize “exceptions” to MAP | |
| Best Practice Nº11: | Taxpayer presentations to competent authorities | |
| Best Practice Nº12: | Cooperation and transparency | |
| Best Practice Nº14: | Face-to-face meetings between competent authorities | |
| Best Practice Nº14: | Bilateral process improvements | |
| Best Practice Nº15: | Decision summaries | |
| Best Practice Nº16: | Recommendation for MAP cases beyond two years | |
| Best Practice Nº17: | Avoid blocking MAP access via audit settlements or unilateral APAs | |
| Best Practice Nº18: | Interest relief | |
| Best Practice Nº19: | Suspension of collections during MAP | |
| Best Practice Nº20: | Readily available access to a competent authority | |
| Best Practice Nº21: | Independence and resources of a competent authority | |
| Best Practice Nº20: | Performance indicators for the competent authority function and staff | |
| Best Practice Nº23: | Implementing and promoting ACAP and bilateral APA programs |
| Return to index |
Documents connexes