Under Mutual Agreement Procedure

In practice, relatively few cases have been referred to arbitration. Figures published in July 2019 by the European Union`s Joint Forum on Transfer Prices, which show that statistics on kremate pending under the arbitration agreement at the end of 2018 show that there have been 932 live cases in the Member States; However, only two live cases were being adjudicated. In order to avoid double taxation due to possible measures taken by the tax administrator of another state in connection with the future controlled transaction, it is desirable to ask, by asking for the alignment of the principles of pricing of future controlled transactions and the conclusion of the agreement with the competent authority of another foreign state, in accordance with the provisions of the applicable tax treaty between the Republic of Lithuania and another State, in order to avoid double taxation of income and capital. Once the application has been submitted, the procedure of mutual agreement can be initiated in accordance with the procedure provided for by the acts. The Mutual Agreement Procedure (“MAP”) is a dispute resolution mechanism provided for by the map article of our double taxation agreements (“DBA”). It is an organization through which the IRAS and the competent foreign authority (CA) settle disputes relating to the application of the DBA. Normally, a MAP has entered between two CAs, but it is also possible that the IRAS enters a multilateral MAP with three or more CAs. The IRAS recognizes the importance of tax security in the rapidly changing business environment and is committed to helping taxpayers resolve tax disputes consistently and principledly, in accordance with recognized international tax rules and principles. When a Singapore tax subject is subject to double taxation as a result of adjustments made either by the IRAS or by a foreign certification body to transfer prices for its transactions with related parties, it may apply to the IRAS to resolve the double taxation through a MAP. For more information, see the Map profile of Singapore (595 KB). Singapore has been peer-reviewed at Level 1 within the OECD/G20 Base Erosion and Profit Shifting Project (BEPS) – Action 14. The “peer review report,” which reflects the results of Singapore`s assessment of the implementation of Minimum Standards of Action 14 (accompanied by a “best practice report” on the implementation of best practices in Singapore), was published on 12 March 2018.

These reports are available on the OECD website. The process of mutual unification (POP) remains the most widely used way and the best way to eliminate double taxation. The effective use of PPIs by different instruments has been of interest to the OECD and the EU for more than 20 years.

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