Our International Tax Group unpacks recent IRS guidance and public comments that reveal how the agency is changing its advance pricing agreement (APA) procedures. The Large Business.
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The Mutual Agreement Procedure ( MAP ) is a useful
dispute resolution mechanism for multinational companies facing a
transfer pricing or other assessment resulting in double tax,
whether in the U.S. or abroad. In order to fully avail themselves
of the advantages of the MAP process, taxpayers should pay careful
attention to the applicable procedures to optimize their chances of
a successful resolution.
Scope of MAP. MAP is a process established by
income tax treaties to relieve double taxation arising from tax
assessments proposed by one treaty jurisdiction that result in the