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Guide to mutual agreement procedures

Cost of requesting a mutual agreement procedure

As a general rule, requesting a mutual agreement procedure does not involve any cost for the taxpayer, beyond the costs incurred by themselves submitting the request for initiation or to comply with any requests for information and documentation received from the competent authorities.

Nevertheless, it should be borne in mind that if the mutual agreement procedure is conducted under the mechanism established in Directive (EU) 2017/1852 and the taxpayer:

  • withdraws from the mutual agreement procedure, or

  • requests the constitution of an advisory commission to determine whether initiation of the procedure should be allowed and that commission decides the competent authorities in question were correct in rejecting initiation,

the competent authorities of the Member States concerned may agree that the taxpayer should bear the expenses and fees of the independent persons who make up the advisory commission.