Mutual Agreement Procedure and Arbitration

Key requirements

Initiate MAP when inconsistent taxation has occurred or is almost certain, not merely because an audit is possible. Apply within the relevant treaty’s time limit, which may be three years but must be checked for that agreement. Singapore residents generally approach IRAS; a non-resident with a Singapore branch generally applies in its residence jurisdiction under the relevant DTA. Some treaties include mandatory binding arbitration for unresolved issues after a specified period and written request; not every Singapore treaty contains it. Review the applicable competent authority agreement and arbitration provisions. Domestic objection rights and MAP are different procedures and should be managed with their respective deadlines.