Mutual Agreement Procedure access governs MAP applications, acceptance, negotiation, implementation of MAP outcomes and procedural requirements. Mutual Agreement Procedure (MAP) under India's DTAAs provides an alternative dispute resolution route for double taxation or taxation not in accordance with treaty terms. Taxpayers apply to the Competent Authority of their residence in Form No. 34F with prescribed facts and documents. The CAs exchange position papers, negotiate bilaterally or multilaterally, and formalise mutual agreements. The guidance defines admissible issues, grounds for denial of access, technical constraints on downward adjustments, treatment of interest/penalties and secondary adjustments, interaction with APAs, and procedures and timelines for implementing MAP outcomes in India.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Mutual Agreement Procedure access governs MAP applications, acceptance, negotiation, implementation of MAP outcomes and procedural requirements.
Mutual Agreement Procedure (MAP) under India's DTAAs provides an alternative dispute resolution route for double taxation or taxation not in accordance with treaty terms. Taxpayers apply to the Competent Authority of their residence in Form No. 34F with prescribed facts and documents. The CAs exchange position papers, negotiate bilaterally or multilaterally, and formalise mutual agreements. The guidance defines admissible issues, grounds for denial of access, technical constraints on downward adjustments, treatment of interest/penalties and secondary adjustments, interaction with APAs, and procedures and timelines for implementing MAP outcomes in India.
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