Survey on MAP vs a local tax trial – which takes precedence?

The Global Tax Controversy (GTC) team is a leading platform for sharing knowledge and experience in the area of international tax litigation and mediation.


In this paper members of the network share the local legislations regarding the Mutual Agreement Procedure (“MAP”) and its interaction with tax court decisions. On this particular scenario, the taxpayer intended to ask the court not to rule in the dispute pending the MAP application. In some jurisdictions, tax court trials do run despite the MAP process being initiated. In other, court decision can nullify the MAP outcome.


Different countries’ positions are shared in this collaborative paper besides the summary of facts and background of question.


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