The UAE Ministry of Finance has published Mutual Agreement Procedure (MAP) guidance to help taxpayers seek relief from double taxation under the country’s extensive tax treaty network.
The document clarifies how taxpayers can access MAP when disputes arise under double tax treaties, such as transfer pricing adjustments or determinations of cross-border permanent establishments. The guidance outlines eligibility criteria, timelines and required documentation, aligning the UAE’s process with OECD standards.
Taxpayers must generally file a MAP request within three years of becoming aware of potential double taxation. The guidance also notes that decisions from UAE courts or the Tax Dispute Resolution Committee may limit the Competent Authority’s ability to grant relief in cases that proceed through MAP.
To initiate a MAP request, taxpayers must provide a detailed information package. The Competent Authority will then work with its counterpart in the other jurisdiction to resolve the issue, with efforts made to adhere to best practice resolution timelines, subject to the quality and timing of the submission.
The UAE has over 130 tax treaties in force. The Ministry of Finance said the new guidance is designed to provide taxpayers with a consistent framework for determining MAP eligibility, preparing submissions, and navigating bilateral resolution processes.
The document’s release follows global pressure on countries to increase the efficiency of dispute resolution amid rising tax enforcement and cross-border scrutiny. The OECD’s peer review assessments of member and associate countries include MAP effectiveness as a core component.
By issuing formal guidance, the UAE aims to enhance transparency and procedural clarity, thereby potentially improving investor confidence in its tax regime.
