UK produces statement of practice on mutual agreement procedure
September 22, 2010
The draft statement of practice contains some welcome features, such as an openness to arbitration and more guidance on when invoking the mutual agreement procedure is appropriate, believe Murray Clayson and Danny Beeton of Freshfields Bruckhaus Deringer
HM Revenue & Customs (HMRC) have recently launched a public consultation on a draft Statement of Practice (SoP) on the use of the Mutual Agreement Procedure (MAP) under the relevant UK double taxation convention and/or the EU Arbitration Convention. The SoP also describes the UK’s approach to the use of arbitration where MAP is unsuccessful. The SoP will supersede Tax Bulletins 25 and 31.
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