Canada Tax Agency Issues Updated Guidance on MAP Rules Under DTAs

The Canadian Revenue Agency June 1 updated guidance on mutual agreement procedure (MAP) rules under DTAs. Topics covered include: 1) procedures for filing and initiating MAP requests; 2) the eligibility criteria for MAP requests; 3) requests for accelerated competent authority procedures; 4) the MAP application process; 5) conditions for the acceptance of cases under MAP for downward transfer pricing adjustments and foreign tax credits; 6) time limits and confidentiality provisions of MAP requests; 7) procedures for bilateral and multilateral advance pricing arrangements (APAs); and 8) the application of the arbitration procedure and eligible cases. [Canada, Canada Revenue Agency, 06/01/21]

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