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Guide to mutual agreement procedures

c.1 Type of procedure

Taxpayers can choose between three types of mutual agreement procedure:

  • Those conducted under the applicable Tax Treaty, which are regulated in Title II of the Regulation of Mutual Agreement Procedures.

  • Those conducted under the Arbitration Convention, which are regulated in Title III of the RMAP.

  • Those conducted under the Directive, which are regulated in Title IV of the Regulation on Mutual Agreement Procedures.

Clearly identifying the type chosen in the subject line of the request helps the competent authorities to initiate the correct procedure immediately, as they do not have to request further information from the taxpayer in that regard.

The reasons for the choice are not necessary.