ATO releases revised guidance on MAP – what does it mean for you? - 18 October 2018
The ATO recently released on its website, revised guidance on the operation of the Mutual Agreement Procedure (MAP) article contained in Australia’s double tax agreements.
The MAP process is a taxpayer activated bilateral tax dispute resolution option and can be initiated following an audit adjustment by one of the tax administrations. Most MAP cases involve transfer pricing matters, however, the process can be initiated by taxpayers on any issue in circumstances where the actions of a tax administration has placed, or has the potential to place, the taxpayer into a position of double taxation.