Extract to table

The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Treaty

Accordingly, PPC must file its MAP request no later than October 12, 2026

Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States

Article 25(3) provides that the competent authorities of the Contracting States shall endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Treaty

It provides that where one Contracting State includes in the profits of an enterprise of that State — and taxes accordingly — profits on which an enterprise of the other Contracting State has been charged to tax in that other State, and the profits so included are profits which would have accrued to the first-mentioned enterprise if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then the other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits

In determining such adjustment, due regard shall be had to the other provisions of the Treaty, and the competent authorities of the Contracting States shall if necessary consult each other