Mutual agreement procedures (MAPs) - Quantera Global Schedule a call

    What’s your question?

    1/4

    What’s your name?

    2/4

    What’s your company name?

    3/4

    How can we reach you?

    4/4

    icon Mutual agreement procedures (MAPs)

    Mutual agreement procedures (MAPs)

    Mutual agreement procedures (MAPs) can be used by taxpayers if they end up in a situation of double taxation due to a transfer pricing correction made by a tax authority. Simply put, the taxpayer requests the competent authorities of the jurisdictions involved to discuss with each other what the arm’s length pricing should have been in order to eliminate double taxation. The MAP is regulated in the OECD Model Tax Convention, tax treaties and the EU Arbitration Convention.

    The MAP usually takes multiple years and within the EU an arbitration process can be requested if there is no agreement within two years. Attention points are amongst others your strategy, managing the process, interest costs and how the secondary adjustment is dealt with.

    Richard Slimmen
    Managing Director

    Do you want to know more about Mutual agreement procedures (MAPs)?
    Please contact us

    Get in touch

    Why are MAPs useful?

    The key benefit is avoiding double taxation while in one jurisdiction the books are closed and in the other jurisdiction a correction is made by the local tax inspector.

    Other benefits include:

    • The related authorities basically approve a transfer pricing methodology for the past and this will give more comfort in applying this methodology going forward.
    • The MAP can have embedded opportunities dependent on your specific situation.
    • The MAP is in most jurisdictions taken care of by transfer pricing specialists of the competent authority and provides for a fresh set of eyes.

    How can QG support?

    When you are faced with double taxation there is often a possibility to start a MAP procedure. At QG, we apply for the procedure and manage the process towards a desirable outcome. We have both a helicopter and in-depth view in this regard. In practice, it is also possible to expand the scope of discussions and turn a single year discussion into a multiple year solution that may save tax expenses.

    If you would like to discuss how we can be of service to you for your Mutual agreement procedures (MAPs), please make an appointment for a free consultation by phone or fill in our contact form. We are looking forward to meeting you

    Yes, I would like to get in touch