Tatacara Persetujuan Bersama (Mutual Agreement Procedure - MAP)
The Article on Mutual Agreement Procedure (MAP) in Malaysia's Tax Treaties allows the Malaysian Competent Authority (CA) to interact with CAs of Treaty Partners with the intent to resolve taxation not in accordance with the provisions of the tax treaty. This includes international tax disputes involving double taxation and inconsistencies in the interpretation or application of the tax treaty on a mutually-agreed basis. The MAP mechanism is independent from the legal remedies available under domestic law.
The MAP Article in Malaysia's Tax Treaties also allows the Malaysian CA to negotiate Bilateral Advance Pricing Arrangement (BAPA) and Multilateral Advance Pricing Arrangement (MAPA) with CA of Treaty Partners. BAPA/MAPA offers assurance that the future set of criteria for the determination of arm's length price/profit on controlled transactions over a fixed period of time will be accepted by the tax administrations of both Malaysia and its relevant Treaty Partners. The MAP Guidelines are applicable to BAPA/MAPA and has to be read together with the Advance Pricing Arrangement (APA) Guidelines.
MAP GUIDELINES 2017 - versi Bahasa Inggeris sahaja
FAQ on MAP (PUBLISHED - 01.02.2023) New! - versi Bahasa Inggeris sahaja
Contact details of Competent Authorities for MAP applications New! - versi Bahasa Inggeris sahaja
Please address enquiries and MAP applications to:
Department of International Taxation
Inland Revenue Board of Malaysia
Menara Hasil, Level 12
Persiaran Rimba Permai
Cyber 8, 63000 Cyberjaya
Telephone : (+603) 8313 8851
Facsimile : (+603) 8313 7748
Email : firstname.lastname@example.org