Double taxation: objecting if your company is not being taxed correctly
How to use the Mutual Agreement Procedure (MAP) if you believe your company is not being taxed in accordance with a double taxation agreement.
Overview of the objection process
Most of the UK’s double taxation agreements contain a provision (called a MAP) allowing a customer to object if they believe they are not being taxed in accordance with the terms of the agreement.
You can present your case to the ‘competent authority’ of the state of which you’re a resident or national if both the following apply:
- you believe you’re not being taxed in accordance with the terms of a double taxation agreement
- the agreement contains a MAP article
This procedure is also referred to as ‘a request for competent authority assistance’.
Within the European Union, taxpayers can also request MAP assistance under the European Arbitration Convention. No new MAP claims will be accepted under the Convention from 1 January 2021.
HMRC has published a Statement of Practice about the use of MAP.
Who to contact for assistance with MAP
If you would like to present a case for MAP assistance, send details to one of the following addresses or emails:
For transfer pricing and general cases :
FAO MAP lead
HMRC, Business Assets and International
S1727, Stratford Regional Centre
Room B7.28
Central Mail Unit
Newcastle NE98 1ZZ
United Kingdom
Email: map.mailbox@hmrc.gov.uk
For all other cases:
FAO David Price
HMRC, Business Assets and International
S1727, Stratford Regional Centre
Room B7.28
Central Mail Unit
Newcastle NE98 1ZZ
United Kingdom
Email: david.e.price@hmrc.gov.uk
Call HMRC for help with other case enquiries.
Telephone: 03000 585 992
Outside UL: +44 03000 585 992
Opening times: 24 hours a day, 7 days a week.
Further information
Tax treaties, double taxation agreements and other agreements.
Read about MAP in the HMRC International Manual.
Updates to this page
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Contact information to use to get help with the Mutual Agreement Procedure has been updated.
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Contact information for who to contact for assistance with the Mutual Agreement Procedure has been updated.
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Section 'Overview of the objection process' has been updated. No new MAP claims will be accepted under the Convention from 1 January 2021.
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Change of name and address for who to contact for assistance with MAP.
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First published.