Competent Authorities respond to increased mutual agreement procedure cases

Tax Insights ()

On December 15, 2011, at the 24th Annual GW-IRS Institute on Current Issues in International Taxation (co-sponsored by the Internal Revenue Service and George Washington University), a panel including officials from the Internal Revenue Service ("IRS"), Japan National Tax Agency ("NTA"), Canada Revenue Agency ("CRA"), and the Korea National Tax Service ("NTS") discussed the roles of Competent Authority ("CA") and how tax administrations are responding to the increase in government budget deficits and the increase in international business models. The number of Mutual Agreement Procedure ("MAP") cases has been growing at a significant rate as a result of increased cross-border trade and investment, including increased foreign direct investment and exports. Factors driving increased cross-border trade and investment include greater access to markets, investments into emerging markets, proximity to resources, global production supply chains, vertical specialization, a decline in transportation costs and tariffs, and improved infrastructure services. At the same time that these investments are occurring, many governments are facing significant budget deficits, which have placed pressure on tax administrations to collect more revenue. The panel cited the following debt to gross domestic product ratios in 2010: