Mutual Agreement Procedure in Switzerland
Lic. iur. Pascal Duss & Dr. Jessica SalomCHF 28.15
Inhalt
1 Introduction 4
2 Scope oft he paper 4
3 Definiiton of a MAP 5
4 Relationshsip betwwen a MAP and the taxation procedure, including domestic remedies 6
5.1 Where to open a MAP 7
5.2 Conditions for a MAP request 7
5.2.1 A Person
5.2.2 Actions of one or both of the contracting states that
result or will result in taxation not in accordance with
theprovisionsoftheConvention 8
5.2.3 Arequestwithinacertaintimeframe 9
5.3 An objection that appears to be justified 9
5.4 Process required to open a MAP 11
6 The MAP proper 12
7 Implementation of the mututal agreement 13
7.1 Revision of the taxation decision 13
7.2 Secondary adjustements 15
7.3 Increase in taxation in Switzerland through a MAP 15
8 Chosen statistical data on MAP 15
9 Conclusions 16
Biography 16
Official Documents 17
Court Decisions 17
1 Introduction 4
2 Scope oft he paper 4
3 Definiiton of a MAP 5
4 Relationshsip betwwen a MAP and the taxation procedure, including domestic remedies 6
5.1 Where to open a MAP 7
5.2 Conditions for a MAP request 7
5.2.1 A Person
5.2.2 Actions of one or both of the contracting states that
result or will result in taxation not in accordance with
theprovisionsoftheConvention 8
5.2.3 Arequestwithinacertaintimeframe 9
5.3 An objection that appears to be justified 9
5.4 Process required to open a MAP 11
6 The MAP proper 12
7 Implementation of the mututal agreement 13
7.1 Revision of the taxation decision 13
7.2 Secondary adjustements 15
7.3 Increase in taxation in Switzerland through a MAP 15
8 Chosen statistical data on MAP 15
9 Conclusions 16
Biography 16
Official Documents 17
Court Decisions 17
