OECD - Application of Mutual Agreement Procedure Article under the Multilateral Instrument to Covered Tax Agreements
- A.K.K. Chan
- Asia-Pacific Tax Bulletin, 2019 (Volume 25), No 2
- 28 February 2019
The author traces the development of the mutual agreement procedure article and the reservations for the MAP article under the multilateral instrument. With examples drawn from some selected contracting jurisdictions holding different positions on the MLI, he illustrates how the MAP article is applied to the respective covered tax agreements and offers his comments accordingly.