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.
If you believe you’re not being taxed 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. No new MAP claims will be accepted under the Convention from 1 January 2021.
HMRC have 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, please send details to the addresses below.
For transfer pricing and general cases :
FAO Ahmed Dar or Ryan McMahon
HMRC, Business Assets & International
S1727, Stratford Regional Centre
Room B8.22
Central Mail Unit
Newcastle NE98 1ZZ
United Kingdom
Telephone: +44(0)3000 599926 or +44(0)3000 542657
Email: ahmed.dar@hmrc.gov.uk or ryan.mcmahon1@hmrc.gov.uk
For all other cases:
FAO David Price
HMRC, Business Assets & International
S1727, Stratford Regional Centre
Room B8.22
Central Mail Unit
Newcastle NE98 1ZZ
United Kingdom
Telephone: 03000 585 992
For customers outside the UK Telephone, +44 03000 585 992.
Email: david.e.price@hmrc.gov.uk
Further information
Tax treaties, double taxation agreements and other agreements
Last updated 6 May 2022 + show all updates
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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.