KPMG report: MAP and the exhaustion of remedies for FTC purposes
The role of mutual agreement procedure (MAP) requests in compulsory payment determinations under the foreign tax credit rules
New U.S. Treasury regulations have overhauled the definition of creditable foreign income taxes, and Pillar One of the OECD/G20 Inclusive Framework on BEPS is reimagining what tax certainty can and should be. Amid this change, it can be helpful to revisit one area where the rules have not undergone any material change: the role of mutual agreement procedure (MAP) requests in compulsory payment determinations under the foreign tax credit (FTC) rules.
Read a December 2022 report* [PDF 79 KB] prepared KPMG LLP tax professionals
This article originally appeared in Tax Management International Journal (December 2, 2022) and is provided with permission.
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