Guernsey publishes MAP guide for resolving cross-border tax disputes

The government of Guernsey on April 30 published new guidelines for taxpayers on how to take advantage of the mutual agreement procedure (MAP) established in Guernsey tax treaties.

The MAP, added to some of Guernsey bilateral tax treaties, assures that the Guernsey Competent Authority will help taxpayers resolve tax disputes with other nations concerning cross-border transactions. The proceedure is avaliable to both individuals and entities.

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) will modify some of Guernsey’s existing tax treaties on June 1 and in some cases will add a clause allowing taxpayers to request MAP. The new guidance will apply to taxpayers taking advantage of MAP in these treaties, as well.

The new guidance discusses topics such as eligibility to request MAP, time limits, an overview of the MAP process, information required to make a MAP request, the procedures when an agreement is reached or not reached, and arbitration.

 

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