Mutual Agreement Procedure Case

Janelle has played an important role in negotiating unilateral and bilateral APAs for taxpayers and in resolving important TP review cases with the Australian Taxation Office (ATO). Any MAP case that is not an allocation/allocation MAP case is considered a « different » case from MAP. See the table that summarizes the entire MAP 2019 caseload by jurisdiction. In recent years, the OECD has shown sustained momentum and implemented the various measures set out in the final report. For example, the peer review and follow-up process aims to bring countries to justice, both to streamline the map process and to close more pop cases. It can be concluded a posteriori that there are more audits and more adjustments. This has led to increased pressure on the POPs themselves to improve their operation and increased pressure on the competent authorities responsible for eliminating double taxation. . .

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