France Tax Agency Updates Administrative Doctrine on DTA Mutual Agreement Procedures, Advance Pricing Agreements

The French General Directorate of Public Finance April 15 issued an updated administrative doctrine on DTA mutual agreement procedures (MAPs) and advance pricing agreements (APAs). Topics covered include: 1) eligibility and conditions for MAP applicants, including residents and nonresidents where permitted under DTAs or the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI); 2) the three-year filing period, from the date the applicant becomes aware of the assessment in question; 3) procedures for settling EU disputes; 4) proceedings and the closing of MAPs under the OECD Model Tax Convention, including unilateral review, ...