c. Detailed content
- c.1 Type of procedure
- c.2 Who are the other parties involved in the transactions under examination and how do I identify them?
- c.3 Identification of the competent foreign tax authority
- c.4 The article of the convention which the taxpayer believes not to have been applied correctly and the taxpayer’s own interpretation of that article, explaining the reason for which the taxpayer believes there to be a question covered by the procedure.
- c.5 Identification of the tax or settlement periods concerned
- c.6 Detailed description of the relevant facts and circumstances of the case
- c.7 The amounts in question in the currencies of the states concerned
- c.8 Details regarding the relationships, situations or structure of the transactions between the persons concerned
- c.9 Nature and date of the actions giving rise to the question to be covered by the procedure, including, where applicable, details of the same income received in the other member state concerned and of inclusion of such income in the taxable base in that state, and details of the tax charged or that will be charged in relation to such income in the other state concerned
- c.10 Details of any administrative or judicial appeals brought by the applicant or by the other parties involved, as well as any decisions issued regarding the same question
- c.11 Indication of whether the taxpayer has previously submitted a request to any of the competent authorities involved, within the framework of a mutual agreement procedure regulated in this regulation and regarding the same or a similar question
- c.12 Declaration stating whether the request includes any question which may be regarded as forming part of an agreed prior assessment procedure or another similar procedure
- c.13 Commitment by the applicant to respond as completely and quickly as possible to all requests made by the tax authority and to provide the tax authority with the documentation relating to the case
- c.14 Date and signature of the applicant or their representative
- c.15 Do I have to submit any documentation with my request for initiation?