Double taxation: objecting if your company isn't being taxed correctly

How to use the Mutual Agreement Procedure (MAP) if you believe you're company isn't 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 aren’t being taxed in accordance with the terms of the agreement.

If you believe you’re being taxed not in accordance with the terms of a double taxation agreement and the agreement contains a MAP you can present your case to the ‘competent authority’ of the state of which you’re a resident or national. 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.

HM Revenue and Customs (HMRC) have published a Statement of Practice, SP1/11 about the use of MAP.

Who to contact for assistance with MAP

If you would like to present a case for MAP assistance, please send details to the addresses below.

For transfer pricing and general cases :

Martin O’Rourke
HMRC, Business Assets & International
Portcullis House
21 India Street
G2 4PZ

Telephone: 03000 515912

Contact martin.o’ by email.

For customers outside the UK Telephone, +44 3000 515912

For all other cases:

David Price
HMRC, CTIAA Business International
3rd Floor, 100 Parliament Street

Telephone: 03000 585 992

For customers outside the UK Telephone, +44 03000 585 992.

Contact by email

Further information

Tax treaties, double taxation agreements and other agreements

Read about MAP in the International Manual

Published 18 February 2014
Last updated 9 November 2017 + show all updates
  1. Change of name and address for who to contact for assistance with MAP.

  2. First published.