My company got hit with cross-border double taxation — how does the Mutual Agreement Procedure help?

The Mutual Agreement Procedure (MAP) is a mechanism written into most of the UAE's double tax treaties, giving a taxpayer a formal route to request relief from economic double taxation — cases where the same income is taxed in more than one country, such as a transfer pricing adjustment between related parties, or a dispute over whether a cross-border permanent establishment exists. The UAE's Competent Authority (under the Ministry of Finance) negotiates with its counterpart in the other jurisdiction to reach a resolution, aiming to follow OECD best-practice timelines, though the final outcome still depends on how cooperative the other jurisdiction's competent authority is.

The general deadline to raise a MAP request is 3 years from when the taxpayer becomes aware that double taxation may occur or has occurred, and the request must come with a detailed information package laying out the case and its legal basis. This is a supplementary route, not a substitute for a domestic reconsideration request or the Tax Disputes Resolution Committee — it's specifically for cross-border tax issues arising under an international treaty, and it fits best for businesses with international transactions or a presence in more than one country. RASEEKH helps clients assess whether their case genuinely warrants a MAP request and prepares the technical file it requires.