Tax Code Provisions on the Specific Case Mutual Agreement Procedure: A Commentary

Article 108-1 of the Tax Code of Ukraine, added in January 2020, establishes specific rules regarding the mutual agreement procedure (MAP). In this note, the author analyses the personal scope of MAPs under article 108-1, as well as some substantive and procedural features. In concluding, the author suggests certain amendments aimed at making resolution of individual cases of taxation not in accordance with tax treaty provisions more effective and efficient.