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Japan's NTA Releases Guidance On MAP Article

by Lorys Charalambous, Tax-News.com, Cyprus

06 October 2017


Japan's National Tax Agency has released guidance on the mutual agreement procedure article found in many of Japan's double tax treaties.

The MAP article is intended to facilitate the resolution of international tax disputes between tax treaty partners. These usually involve cases of double taxation, as well as inconsistencies in the interpretation and application of a treaty.

The majority of MAP cases are intended to resolve uncertainty with regards the taxing rights over income by an individual or business situated in one or other or both territories.

Most MAP articles found in double tax treaties are now based on Article 25 of the OECD Model Tax Convention.

The guidance released by the National Tax Agency in Japanese is in the form of answers to frequently asked questions. It is based on recommendation 2.1 of the final report on Action 14 (Making dispute resolution mechanisms more effective) of the OECD's base erosion and profit shifting (BEPS) project. This says: "Countries should publish rules, guidelines, and procedures to access and use the MAP and take appropriate measures to make such information available to taxpayers."

The guidance released by the National Tax Agency is in addition to the Japanese tax commissioner's directive on MAP administrative guidelines.

TAGS: tax | double tax agreement (DTA) | Organisation for Economic Co-operation and Development (OECD) | Japan | Tax | BEPS

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