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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
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A new provision establishes the requirements for the suitability of transfer pricing documentation. In order to align the domestic transfer pricing framework with the Organisation for Economic Cooperation and Development standards, the provision updates the rules relating to the content of transfer pricing documentation, which must be prepared in order to support the application of the arm's-length principle to intercompany transactions.
2021-01-12 11:36:12
Ulaanbaatar /MONTSAME/. On 22 December 2020, Oyu Tolgoi LLC received a Tax Assessment claim for approximately US$228 million from the Mongolian Tax Authority (MTA), relating to an audit of taxes paid by Oyu Tolgoi LLC between 2016 and 2018. The MTA has also sought to reduce Oyu Tolgoi’s carried-forward tax losses by around US$1.5 billion.
On 11 January 2021, Oyu Tolgoi LLC issued a press release regarding the tax matters, which reads, “Oyu Tolgoi LLC consistently recognized as one of the largest taxpayers in Mongolia. It has paid more than MNT5.8 trillion (approximately US$2.8 billion) in taxes, royalties and fees to the Government of Mongolia since 2010.”