2021 Guidance on MAPs

Abstract

The mutual agreement procedure (MAP) is an instrument for the resolution of international tax disputes whenever a person considers that the actions of the tax authorities result in taxation not in accordance with the provisions of a tax treaty or an international agreement. The current article analyses Hungary’s recent MAP guidelines regarding double tax treaties, a dispute resolution directive, and arbitration convention-based MAPs, and their application to transfer pricing cases. It also elaborates on the recent structural changes within the competent authorities.