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MUTUAL AGREEMENT PROCEDURE - bcasonline.org

MUTUAL AGREEMENT PROCEDUREB ombay Chartered Accountants SocietyDTAA Course 2014-15CA T P provisions Article 25 OECD Treaty Model of Some of issues under MAP Amendments Regime MAPs in India statistics & AssociatesJanuary 2015 Background NEED & IMPORTANCE OF RESOLVING INTERNATIONAL TAX DISPUTES Major concern for business and government Disputes have increased in number and this trend will continue Need a more effective PROCEDURE to resolve & AssociatesJanuary 2015 Before Dispute Arises ADVANCE PRICING AGREEMENTS ( TRANSFER PRICING) AUTHOURITY FOR ADVANCED RULING After Dispute Arises MUTUALAGREEMENTPROCEDURES(MAP) ARBITRATION COMPULSORYorOPTIONAL INTERNATIONALLITIGATION INTERNATIONALCOURTOFJUSTICEEUROPEANCOURT OFJUSTICE(ECJ)INTERNATIONAL TAX DISPUTE REDRESSAL & AssociatesJanuary -MAP If taxation not in accordance with tax treaty, taxpayer may need to litigate in one or both of contracting states.

MUTUAL AGREEMENT PROCEDURE Bombay Chartered Accountants Society DTAA Course 2014-15 CA T P Ostwal

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