Mutual Agreement Procedure and Mandatory Arbitration (BEPS Action) and India’s stand
MAP is a mechanism laid down in tax treaties to ensure that taxation is in accordance with the tax treaty. This can also be invoked when a tax payer suffers or is likely to suffer an adverse action during transfer pricing audit to avoid economic double taxation. In the event that his case falls under the domain of Article 24 (1), then a similar instance of the candidate can be displayed to the skilful state expert of which he is a national. The case ought to be exhibited inside the three years of such notice. The citizen for the situation can summon the MAP where he considers that the activity of it is possible that one or both the gatherings will make erroneous burden of assessment. It is not required that the mischief has as of now been brought on. In the event that the individual can secures any irregularity in the duty structure, which he is subjected to, he can summon the same under the MAP procedures. As said under the article 2