Mutual Agreement Procedure ( definition
Mutual Agreement Procedure ( means a mutual agreement procedure contained in arrangements having the force of law by virtue of section 826 of the Act of 1997 and the procedures for the purpose of resolving difficulties arising out of the application of those arrangements;
Mutual Agreement Procedure ( is the term given to the provisions that are designed to provide a method of resolving difficulties arising out of the application of a particular agreement, and to provide for consultation with a view to reaching a satisfactory solution where a taxpayer is subject to taxation contrary to the provisions of the agreement. Typical examples of circumstances within the procedure are given in the OECD commentary to Article 25 of both the 1977 and 1922 OECD Model Conventions. Where a person considers that the actions of one or both of the States result or will result for him in taxation not in accordance with the provisions of this Treaty, he may present his case to the competent authority of the State of which he is resident. If not resident in either State (but a national of one of them) the case must be presented to the State of which he is a national. This is so irrespective of the remedies provided by domestic law. The two tax authorities will try to resolve the case by mutual agreement. They will also try to agree on definitions of terms not specifically defined in the Treaty and on general matters of interpretation of the Treaty. Thus this Article removes the need for the tax authorities in each State to go through diplomatic channels; they may simply contact each other directly. The mutual agreement procedure is commonly used to decide matters concerning income and expense allocations and transfer pricing.
Mutual Agreement Procedure (. MAP’)” – A means through which tax administrations consult to resolve disputes regarding the application of double tax conventions. This procedure, described and authorized by Article 25 of the OECD MTC and Article 25 of the UN MTC, can be used to eliminate double taxation that could arise from a transfer pricing adjustment.14