Part two.FAQs
- Compatibility with certificates of agreement/approval
- Compatibility with appeals/claims
- Compatibility with penalties
- Compatibility with anti-abuse clauses
- Suspension of collection of tax debt
- Rights of the taxpayer in the mutual agreement procedure
- Agreement does not constitute a precedent
- Accrual of late-payment interest
- Non-initiation of a mutual agreement procedure in the absence of a tax assessment, for example, on the basis of a simple self-assessment that 'gives rise' to double taxation
- Can a mutual agreement procedure relating to transfer pricing be requested under a tax agreement when that convention does not include an article equivalent to Article 9.2 of the OECD's model tax convention on income and on capital?
- Cost of requesting a mutual agreement procedure
- Incomplete application for initiation
- Refusal to initiate the mutual agreement procedure
- Mutual agreement procedure to discuss interest and penalties
- Application of agreements reached between competent authorities regardless of domestic limitation periods
- Publication of agreements reached between competent authorities in the context of mutual agreement procedures
- Arbitration stage
- Possibility of multilateral mutual agreement procedures