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Guide to mutual agreement procedures

Part two. Frequently asked questions (FAQ)

  1. Compatibility with audit settlement or assessments with the taxpayer’s agreement
  2. Compatibility with appeals/claims
  3. Compatibility with penalties
  4. Compatibility with anti-abuse provisions
  5. Suspension of tax collection.
  6. Rights and obligations of the taxpayer in the mutual agreement procedure
  7. Mutual agreement does not have precedential value
  8. Accrual of late-payment interest
  9. Non-initiation of a mutual agreement procedure in the absence of a tax assessment, for example, on the basis of a self-assessment that ‘gives rise’ to double taxation. “generate” double taxation
  10. Can a transfer pricing mutual agreement procedure be requested under a tax treaty when that tax treaty does not include an article equivalent to article 9.2 of the oecd model tax convention on income and on capital?
  11. Cost of requesting a mutual agreement procedure
  12. Incomplete mutual agreement procedure request
  13. Denial to initiate the mutual agreement procedure
  14. Mutual agreement procedure for discussing the interest and penalties
  15. Implementation of mutual agreements regardless of the expiration of domestic statute of initiation.
  16. Publication of mutual agreements
  17. Arbitration Stage
  18. Possibility of multilateral mutual agreement procedures