Mutual Agreement Procedure for DTAs

The Mutual Agreement Procedures (“MAP”) are often found in Double-Taxation Agreements (“DTAs”). MAPs are used as means for settling double-taxation disputes by non-contentious means.

Under Normative Ruling 1,669/2016, a MAP can either operate as a unilateral stage used by the Brazilian Federal Revenue Department (“RFB”) to assess and decide on the avoidance of double taxation or operate as a bilateral stage whereby the RFB engages with their foreign counterpart so that both reach a mutually-agreed solution over the controversy and set tax collection terms.

Both residents and non-residents affected by double-taxation can request the application of the MAP. The MAP may not be requested if the taxpayer has filed court proceedings.

Contact us if you require further information.

Double Tax Agreements

Last modified: November 25, 2017