Applying for a mutual agreement procedure (MAP)
You can apply for a mutual agreement procedure (MAP) if you are subject to double taxation or if you believe that your income has been taxed in breach of a bilateral tax treaty.
Double taxation may take two forms:
Legal, i.e. you are taxed on the same income in two States
Economic, i.e. when taxation of the income of a taxpayer in one State duplicates taxation of the income of another taxpayer who is related to the first in another State. This is particularly common for the transfer of profits between companies belonging to the same group.
You can however only apply for a MAP for the taxes covered in the relevant treaty. To do so, consult the list of taxes referred to in the “Taxes covered” article of the relevant treaty.