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Suspension of tax collection during MAP allowed on furnishing bank guarantee; enforcement abeyance until MAP resolution. The India UK MOU provides that collection of disputed taxes, interest and penalties shall be suspended during MAP where the Indian Competent Authority has admitted the taxpayer's MAP case and the taxpayer furnishes an irrevocable bank guarantee in the prescribed model for the amount of tax disputed plus interest. The bank guarantee qualifies as sufficient security to permit the Assessing Officer to keep recovery in abeyance and to extend time for payment under domestic law while MAP is pending. The guarantee may be invoked only after notice between competent authorities if MAP yields no resolution or the taxpayer fails to pay pursuant to a MAP disposition; substitution, renewal and limits on security are provided in the MOU and Annexure.
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Suspension of tax collection during MAP allowed on furnishing bank guarantee; enforcement abeyance until MAP resolution.
The India UK MOU provides that collection of disputed taxes, interest and penalties shall be suspended during MAP where the Indian Competent Authority has admitted the taxpayer's MAP case and the taxpayer furnishes an irrevocable bank guarantee in the prescribed model for the amount of tax disputed plus interest. The bank guarantee qualifies as sufficient security to permit the Assessing Officer to keep recovery in abeyance and to extend time for payment under domestic law while MAP is pending. The guarantee may be invoked only after notice between competent authorities if MAP yields no resolution or the taxpayer fails to pay pursuant to a MAP disposition; substitution, renewal and limits on security are provided in the MOU and Annexure.
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