The advance pricing arrangement and the mutual agreement procedure
Publié le 20/02/2017, modifié le 14/02/2025 Lecture 1 minute
The advance pricing arrangement (APA) is a tax ruling that provides businesses with legal certainty with respect to their future transactions between two related companies.
The purpose of the mutual agreement procedure (MAP), which is independent of any domestic remedy, is to resolve situations of double taxation or situations in which taxation is non-compliant with a bilateral tax convention.
Mutual agreement procedure
The mutual agreement procedure (MAP) is an out-of-court procedure provided for in bilateral tax conventions which aims to eliminate the double taxation of taxpayers. It is independent of any domestic law remedies.
Advance pricing arrangement
The advance pricing arrangement (APA) is a tax ruling that provides businesses with legal certainty with respect to their intra-group transactions.
Questions fréquentes
Who can apply for a MAP ?
20 février 2017
How and where do I file the MAP application ?
20 février 2017
What type of APA is appropriate for me ?
20 février 2017
How and where do I file the APA request ?
20 février 2017