Bahrain’s National Bureau of Revenue in September issued guidance on the mutual agreement procedure (MAP) for resolving international tax and transfer pricing disputes. The guidance is intended to assist taxpayers considering submitting MAP requests and to facilitate the competent authority process.
The guidance specifies the information required to be included in MAP requests. This includes details on the taxpayer, information on relevant related parties for transfer pricing cases, information on the person that withheld tax in withholding tax cases, relevant tax years, and a description of the facts and issues, among other information.
Taxpayers should submit their MAP requests to the competent authority of the country in which they are resident. Requests must be submitted within the timeframe specified in the applicable double tax treaty.
Bahrain’s competent authority will only accept MAP requests if the issue relates to a jurisdiction with which Bahrain has a tax treaty, if there is apparent taxation not in accordance with the applicable treaty, and if the taxpayer has submitted the request within the timeframe specified in the treaty. Bahrain currently has 45 double tax treaties in force, which are listed in the MAP guidance.
For accepted MAP requests, the guidance further sets out the steps for competent authority actions under the MAP process and the timeframes in which they are to be completed.
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