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 :
HMRC, Business Assets & International
21 India Street
Telephone: 03000 515912
Contact martin.o’firstname.lastname@example.org by email.
For customers outside the UK Telephone, +44 3000 515912
For all other cases:
HMRC, CTIAA Business International
3rd Floor, 100 Parliament Street
Telephone: 03000 585 992
For customers outside the UK Telephone, +44 03000 585 992.
Contact email@example.com by email