Chapter INTM423130
| Published date | 09 April 2016 |
| Record Number | INTM423130 |
For Requests under the Relevant Tax Treaty
...
| Steps and information required | |
|---|---|
| 1 | The year(s) concerned. |
| 2 | The tax convention article(s) that the taxpayer asserts is not being correctly applied, and the taxpayer’s interpretation of the application of the article. |
| 3 | The full names and addresses of the parties to which the MAP relates. |
| 4 | The UK party’s HMRC office and reference number |
| 5 | For requests submitted by an agent, signed authority for the agent to act. |
| 6 | HMRC Customer Compliance Manager or HMRC other contact. |
| 7 | Where the request is in respect of a UK adjustment, the international specialist or other HMRC officer responsible for the enquiry that lead to the adjustment |
| 8 | UK tax computations for all years concerned. In the case of a UK adjustment computations before and after the adjustment. |
| 9 | For overseas adjustments, details of and legal or administrative process that affects the MAP. Has the overseas state denied or suspended MAP as a result of a particular domestic legal or administrative process? |
| 10 | Contact details for the overseas competent authority, if the claim has already been made to the other country. |
| 11 | Details of previous requests, if the request relates to an issue that is the same as an issue that has been subject to an earlier request. |
| 12 | Exchange rates used. |
| 13 | For transfer pricing cases, the name, address and, if possible, the taxpayer identification number of any related foreign taxpayer involved |
| 14 | The relationship, situation, or structure of the transactions, issues, or related parties involved (advising of any changes in these matters that occur after the request has been filed would be helpful). |
| 15 | A summary of the facts and an analysis of the issues for which competent authority assistance is requested, including any specific issues raised by the tax administrations affecting the taxpayer and the related amounts (in both currencies and supported by calculations, if applicable). |
| 16 | For transfer pricing cases, documentation as described in domestic legislation of the taxpayer’s state of residence if available (where documentation is inordinately voluminous, a description of the documentation prepared in connection with the transactions which are the subject of the MAP request may be acceptable). |
| 17 | A copy of any other relevant competent authority request and the associated documents filed, or to be filed, |
To continue reading
Request your trial