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Mutual Agreement Procedure in India – Transfer Pricing

Facilitating Resolution with TPverse’s Mutual Agreement Procedure Services

TPverse consistently offers the highest quality tax dispute resolution in mutual agreement procedure by combining innovation and integrity in their approach. Their mission is to make sure that their clients understand the complex world of mutual agreement procedure transfer pricing and that they comply with all applicable advance pricing obligations.

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Decoding Mutual agreement procedure In India

Under the DTAAs, taxpayers have access to the Mutual Agreement Procedure (MAP), an alternative tax dispute resolution process, to settle disagreements that could result in double taxation or taxation that is not compliant with the DTAAs. 

When a taxpayer believes that the conduct of one or both of the treaty partners’ tax authorities result in or may result in taxation that is not in compliance with the applicable DTAA, the taxpayer may submit a MAP request which will lead to tax dispute resolution in mutual agreement procedure.

TPverse’s Mutual agreement procedure Service In India

At TPVerse, they  assist and represent you during the Mutual Agreement Procedure (MAP) by assessing all available information-

  • TP modification and a review of all TP documents.
  • Drafting a request to the Competent Authority (the “CA”) and having a conversation with the CA.
  • Settlement and termination of the MAP.

MAP Evaluation, Preparation, and Documentation

The purpose of the Manual on Effective Mutual Agreement Procedures (MEMAP) is to serve as a guide to raise understanding of the MAP process and its proper operation. It will identify best practices for MAP and give taxpayers and tax administrations a basic understanding of how it operates without imposing a set of legally enforceable regulations on Member nations.

Representation and Negotiation before Competent Authority

TPVerse’s objective is to minimize any potential tax adjustments that may come as a result of the dispute, from drafting an analysis and defense of the policies in question to helping with the information exchange. They can provide you with advice regarding alternative dispute resolution procedures like APA and MAP.

Post MAP Compliance Support

In order to prevent double taxation, ensure that tax treaties are implemented effectively, and settle cross-border tax disputes in a fair and equitable manner, MAP is essential. MAP is an important tool for strategically lowering compliance risk and TPVerse provides conflict resolution mechanisms in this regard.

Consult With TPverse’s Expert

TPVerse staff of mutual agreement procedure transfer pricing experts is extremely skilled and experienced, and they can handle projects requiring precise urgency, excellent quality, and individualized attention. Their knowledge, professionalism, and discipline are their key advantages. Consult with TPVerse’s expert now at info@tpverse.in 

Partner With TPVerse for mutual agreement procedure transfer pricing

TPVerse offers the information and insights necessary for your business to succeed when it comes to guidance on mutual agreement procedure in the future. Link your company’s goals with TPVerse’s to get the best mutual agreement procedure consultants and seamless MAP solutions.

FAQ’s

Why are annual reports on MAP Statistics made?
MAPs and other dispute resolution procedures are essential to a healthy network of tax treaties. A peer review mechanism is included in the BEPS Action 14 Minimum Standard, which was adopted in 2015 by the members of the OECD/G20 Inclusive Framework on BEPS ("IF") with the aim of enhancing the resolution of tax-related disputes between jurisdictions. The mechanism is designed to assess and track member jurisdictions' adherence to the minimum standard.
When is it possible to get a MAP?
When you believe that the actions of tax administrations, or the tax administrations of its Treaty Partners, or both, result in or may result in taxation that is not in compliance with the Double Taxation Avoidance Agreement (Tax Treaty), you may request a MAP. The issuing of a revised assessment for transfer pricing adjustment, resident status, withholding tax, permanent establishment, and income characterization or categorization are a few examples of such circumstances.
Is it possible for a taxpayer to take part in the discussions between the Competent Authorities?
The negotiations that take place between the competent authorities of the participating nations under MAP are typically conducted behind closed doors. As a result, the taxpayer would not be able to access or take part in the talks between the Competent Authorities.
When is the submission of the MAP deemed official?
The official acceptance of a MAP case does not occur automatically upon the taxpayer's submission of a MAP request. MAP requests will only be approved if they meet the qualifying requirements. As a result, once the CA approves a request that was made it is deemed official.