KPMG report: Accelerated competent authority procedure can extend MAP resolutions to subsequent years
A KPMG report that explains how ACAP and its analogues allow for MAP case resolutions to be rolled forward to subsequent years.
Accelerated competent authority procedure can extend MAP resolutions to subsequent years
The IRS and many tax authorities across the globe offer several mechanisms to resolve cross-border disputes and seek relief from double taxation, including the mutual agreement procedure (MAP) article of relevant income tax treaties.
MAP cases frequently involve transfer pricing issues and generally arise as a result of an adjustment made by a tax authority, but they can also be used for transfer pricing adjustments initiated by a taxpayer to ensure that it is in compliance with the applicable requirements.
The accelerated competent authority procedure (ACAP) complements the standard MAP process by providing an efficient mechanism to extend an agreed resolution to subsequent filed years.
Read a July 2023 report* [PDF 658 KB] prepared by KPMG LLP tax professionals that explains how ACAP and its analogues allow for MAP case resolutions to be rolled forward to subsequent years.
*This article originally appeared in Tax Notes International (July 31, 2023) and is provided with permission.
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