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of <h1>India-UK MoU Suspends Tax Collection During MAP, Requires Bank Guarantee for Transfer Pricing Disputes Under Article 27.</h1> The India-UK Convention for Avoidance of Double Taxation and Prevention of Fiscal Evasion outlines a Mutual Agreement Procedure (MAP) to prevent double taxation. Article 27 allows the Competent Authorities to create procedures for MAP implementation. A Memorandum of Understanding (MoU) between India and the UK suspends tax collection during MAP, requiring a bank guarantee equal to the disputed tax amount. This applies to UK residents and Indian taxpayers involved in transfer pricing disputes. The MoU mandates the suspension of tax collection if MAP is pending, with conditions for bank guarantees. The MoU's provisions are also applicable to Indian taxpayers in transfer pricing cases.
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