International - Solving Double Taxation outside the Realm of a Mutual Agreement Procedure
- E. Vroemen
- International Transfer Pricing Journal, 2019 (Volume 26), No 2
- 4 February 2019
As transfer pricing adjustments are expected to increase, so will be mutual agreement procedure requests in order to remedy the resulting double taxation. To forego the downsides of this procedure, this article suggests that a MAP should be preceded by an attempt to obtain an unilateral corresponding adjustment. In the Netherlands, such an instrument is available and is called a pre-emptive MAP request.