OECD statistics on POPs show that more taxpayers are using the map procedure, given the increase in bilateral tax controls and disputes. The MLI has helped to improve the efficiency and effectiveness of the map process, in line with the intentions expressed in the final report of 5 years ago. The MAP is a process that allows the competent authorities of the contracting parties to interact with the intention of resolving international tax disputes. The competent authorities are obliged to do their best to reach an agreement on tax evasion that does not comply with the MAP article of the relevant tax treaty. In the United Kingdom, the Commissioners for HM Revenue and Customs (HMRC) or their authorized representatives, the delegated authorities of the United Kingdom, have the autonomy to conclude MAP DE agreements in accordance with the provisions of the tax treaty in question, without depending on the approval or direction of HMRC staff who are directly involved in the disputed accommodation and without being influenced by political considerations. It should be noted that, if the POP is the first means of exempting double taxation and a mutual agreement has been reached, the taxpayer will be offered the opportunity to reject the agreement and pursue the available internal remedies. As a result of the BEPS reforms, the OECD acknowledges that the use of POPs will increase as a result of increased audit activities by tax administrations around the world. Over the past five years, the OECD has been committed to making the map process more efficient and efficient and accessible to taxpayers. In the revised guidelines, HMRC also recognizes that there may be circumstances in which foreign tax authorities enter into informal agreements with subjects, provided access to POPs is restricted. Hmrc will continue to consider providing facilities in such circumstances, although the likelihood of a total elimination of double taxation is reduced in cases where dialogue between HMRC and foreign tax administration is limited. 24. A pre-price agreement (APA) is a written agreement that defines a method for resolving transfer pricing issues before restitution. In some circumstances, it may be useful to apply the transfer pricing method used in the APA to previous years that may be the subject of discussion or MAP.
The OECD model contains an article on dispute resolution procedures agreed upon between the relevant authorities (Article 25). The article states that when a person feels that he is not taxed in accordance with the provisions of the convention on double taxation because of the actions of one or both of the contracting states, he has the right to submit a case to the competent authority of his state of residence. This right applies regardless of the remedies available in both states.