Second part. Frequently asked questions (FAQ)
- Compatibility with audit settlement or assessments with the taxpayer’s agreement
- Compatibility with appeals/claims
- Compatibility with penalties
- Compatibility with anti-abuse provisions
- Suspension of tax collection.
- Rights and obligations of the taxpayer in the mutual agreement procedure
- Mutual agreement does not have precedential value
- 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 self-assessment that ‘gives rise’ to double taxation. “generate” double taxation
- Can a transfer pricing mutual agreement procedure be requested under a tax treaty when that tax treaty does not include an article equivalent to article 9.2 of the oecd model tax convention on income and on capital?
- Cost of requesting a mutual agreement procedure
- Incomplete mutual agreement procedure request
- Denial to initiate the mutual agreement procedure
- Mutual agreement procedure for discussing the interest and penalties
- Implementation of mutual agreements regardless of the expiration of domestic statute of initiation.
- Publication of mutual agreements
- Arbitration Stage
- Possibility of multilateral mutual agreement procedures