In February 2023 the OECD published the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAP) and Advance Pricing Arrangements (APAs).
The Manual provides tax administrations and taxpayers with basic information on the operation of multilateral procedures and suggests different approaches based on the existing practices of jurisdictions, without imposing a set of binding rules upon jurisdictions. The Manual allows tax administrations to explore whether the implementation of these procedures is appropriate and to consider whether the guidance therein may be incorporated in their domestic guidance on MAP or APA processes to provide additional clarity.
Kept overviews legal and procedural aspects, advises on ideal timeline for multilateral processes and provides recommendations for taxpayers.
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Tax & Legal
18 April 2023