E Mutual Agreement Procedure

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The double taxation agreement is available on the website of the Federal Ministry of Finance. For more information on applying for a POP and exceptions for individuals, see Chapter 3.4 of the Tax Administration Guidelines on the Procedure for Mutual Agreement in the Case of International Tax Disputes. Competent Authority (institution) – Tax inspectorate of the Ministry of Finance of the Republic of Lithuania. The permanent working group on the handling of double taxation dispute resolution procedures is responsible for handling all map cases. Contact point for issues relating to double taxation dispute resolution procedures: Ms Vaide Riskute, head of the Permanent Working Group on Double Taxation Dispute Resolution Procedures Coordinated: tel. 370 5 2687 847, e-mail: Vaide.Riskute@vmi.lt The Mutual Agreement Procedure (POP) remains the best way to eliminate double taxation. The effective use of PPIs by different instruments has been of interest to the OECD and the EU for more than 20 years. According to bePS, the number of double taxes is increasing and the number of POPs continues to increase. There is a growing emphasis on ensuring better dispute resolution techniques to more effectively eliminate double taxation. This article describes some of the features of the instruments currently available.

In particular, Article 19 of the compulsory arbitration procedure must be mandatory if the competent authorities are unable to reach an agreement on the settlement of a case within two years of their start. This is a significant restriction on POPs cases in the past, as the competent authorities were only required to try to resolve cases and disputes could be resolved indefinitely. Section 19 ensures that treaty disputes will be resolved within a specified time frame, making the MAP a more attractive option for taxpayers. In addition, sections 20 to 25 provide for the practical functioning of arbitration. In the past, it was often practical constraints or a lack of agreement on how to proceed that blocked the solution. Upon receipt of the application, the BZSt verifies whether the conditions for the implementation of a mutual agreement procedure are met.

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