As a part of the cooperation between the IOTA and the OECD in promoting fair and efficient tax systems and exchange of experience among tax administrations, a joint training event on Handling Mutual Agreement Procedure (MAP) cases was held in Budapest, Hungary from 26th to 30th November 2018.
Improving dispute resolution mechanisms is an important part of implementing Package (BEPS Action 14). The aim of the training was to develop both knowledge and practical experience of officials responsible for handling MAP cases to (re)solving tax treaty-related disputes within the competent authority. The event attracted nearly 40 participants from 34 jurisdictions participating in the Inclusive Framework on BEPS, including the delegates from Brazil, Chile, China, Guernsey, Hong Kong (China), Indonesia, Japan and South Korea.
The first part of the training event was bult on presentations OECD FTA MAP Secretariat providing the basics of the MAP in the context of the dispute resolution mechanism under BEPS Action 14, including its origin, legal basis and legal impact, general MAP provisions and the available arbitration instruments. During the second part of the training, delegates analysed and discussed among themselves Advance Pricing Arrangement (APA) and MAP case studies with a view of deepening knowledge about rules, guidelines and procedures of respective MAP programmes implemented in participating countries.
Another important aspect of the MAP training event was related to the development of practical skills of (re)solving APA and MAP cases, especially in terms of preparation of explanatory letters to the taxpayers and the other competent authorities, position paper, conducting negotiations and implementation of MAP agreements. Also, the joint OECD-IOTA training event contributed to establishing interpersonal relationships and diversity awareness, delegates could make useful contacts with MAP specialists from other participating countries.
Further information about the training, including all training material and presentations is available here for IOTA members.