Mutual Agreement Procedure (MAP)

Where a TP adjustment creates double taxation, MAP offers a treaty-based route to resolution — coordinated directly with foreign competent authorities.

Overview

A treaty remedy for cross-border double taxation

When a transfer pricing adjustment in India results in the same income being taxed twice — once in India and once in a treaty partner jurisdiction — MAP allows the two countries' competent authorities to negotiate a resolution, under the Mutual Agreement Procedure article of the applicable tax treaty.

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Who this applies to

Companies facing a TP adjustment that results in economic double taxation across two treaty-partner jurisdictions.

What We Cover

Full MAP lifecycle support

Eligibility Assessment

Confirm treaty coverage and whether MAP is the appropriate remedy.

Application Preparation

Draft and file the MAP application with the Indian competent authority.

Competent Authority Liaison

Coordinate with your overseas advisors and the treaty partner's authority.

Resolution Implementation

Give effect to the agreed resolution in Indian tax filings.

Our Process

Coordinated across both jurisdictions

Step 1

Case Review

Assess the underlying TP adjustment and double taxation exposure.

Step 2

Application Filing

File the MAP request within treaty-prescribed timelines.

Step 3

Negotiation Support

Support the Indian competent authority's negotiation with the treaty partner.

Step 4

Closure

Implement the agreed resolution and close out the dispute.

Why Work With Us

Genuine cross-border coordination, not a one-country view

Treaty Expertise

Deep familiarity with India's tax treaty network and MAP procedures.

Overseas Advisor Coordination

Direct liaison with your foreign tax counsel throughout.

Litigation-Aware Strategy

MAP pursued alongside, not instead of, domestic appellate options where relevant.

FAQs

Common questions

Can I pursue MAP and a domestic appeal at the same time? +

In many cases yes, though the interaction between MAP and domestic appellate proceedings depends on the specific treaty and case facts — we advise on the right sequencing.

How long does a MAP case typically take? +

MAP cases can take anywhere from one to several years depending on the treaty partner, though India has made notable progress in reducing average resolution times in recent years.

Facing double taxation from a TP adjustment?

Talk to our MAP team about your options.