On 12 January 2017, IRAS has updated the content on Mutual Agreement Procedure (MAP) on its website and provided the following information:
- What is MAP?
- Who can apply for MAP?
- When to apply for MAP?
- How to apply for MAP?
In summary, MAP is a dispute resolution mechanism provided under the MAP Article in our Double Taxation Agreements (DTA), in which to allow IRAS and the competent authority (CA) of another contracting state to resolve disputes regarding the DTA application.
If you are a Singapore tax resident who suffers double taxation due to the transfer pricing adjustments effected by IRAS or a foreign CA, it is possible to request IRAS to resolve the dispute through a MAP. MAP is also available to a Singapore branch of a foreign company provided the MAP application is made in the jurisdiction in which the foreign company resides and it has concluded a DTA with Singapore.
If you have any questions regarding the above, please contact firstname.lastname@example.org.