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Guide to mutual agreement procedures

f. To whom should the request for initiation of a mutual agreement procedure be directed?

As a general rule, taxpayers can submit the request for initiation of the procedure only to the competent authority of the state in which they reside.

As an exception, requests for procedures under the Directive must be submitted, at the same time, to all competent authorities involved and be accompanied by the same documentation, except where the taxpayer:

  • is an individual; or
  • Is not a large undertaking and does not form part of a large group, as set out in Article 3(4) and (7) of Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013.

Only those two types of taxpayers can submit a request for the initiation of a mutual agreement procedure under the Directive to just one competent authority (that of the state in which they reside).

To avoid unnecessary delays in handling the procedure, ideally, taxpayers should submit the request for the initiation of the procedure, accompanied by the same documentation, to all competent authorities involved, even if it is not mandatory.

The contact details for all competent authorities in relation to mutual agreement procedures are available on the OECD website (https://www.oecd.org/tax/dispute/country-map-profiles.htm).