In addition, Between India and Korea also have agreed that transfer pricing dispute cases will be taken up for MAP under the revised Double Tax Avoidance Agreement (DTAA) .
What is Mutual Agreement Procedure?
MAP is an alternate dispute resolution mechanism
An experienced authority of particular nation and its contract partner to negotiate a mutually acceptable settlement is certified by MAP.
According to this settlement two signatory sides can negotiate settlement on a case that can subsequently be taken off from the formal legal process.
MAP pulls up parameters for taxation in a country for which credit would be available in another as part of resolution process.
Benefits of MAP:
To settle cross-border tax cases globally MAP is ideal approach.
It eliminates double taxation retiring out of transfer pricing tax arguments and also a characterization of income and attribution of profits and existence of Permanent Establishment.