Govern Andorra,El Govern aprova un nou Reglament de procediments d’arranjament per a la resolució de conflictes en l’àmbit de la doble imposició

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Andorran Government Approves New Regulation for Dispute Resolution Mechanisms in the Context of Double Taxation

Andorra la Vella, November 15, 2024 – The Government of Andorra has approved a new Regulation for dispute resolution mechanisms in the context of double taxation, which will be in force as of today.

The new Regulation is designed to provide a clear and efficient framework for resolving disputes that may arise between taxpayers and the Andorran Tax Authorities regarding the interpretation and application of double taxation agreements (DTAs).

Key Features of the New Regulation

The new Regulation establishes a two-tiered dispute resolution process:

  1. Mutual Agreement Procedure (MAP): The MAP is an administrative procedure that allows taxpayers to request the assistance of the competent authorities of both Andorra and the other country involved in the dispute to resolve the issue. The MAP is typically initiated by the taxpayer filing a request with the competent authority of their country of residence.

  2. Arbitration: If the MAP process is unsuccessful, the taxpayer may request arbitration. The arbitration will be conducted by a panel of three arbitrators, one appointed by each competent authority and the third appointed jointly by the two arbitrators. The decision of the arbitration panel is binding on both parties.

The Regulation also includes provisions on the following:

  • The types of disputes that can be resolved through the MAP and arbitration procedures;
  • The time limits for filing requests for MAP and arbitration;
  • The procedures for conducting MAP and arbitration proceedings;
  • The costs of MAP and arbitration proceedings;
  • The enforcement of MAP and arbitration decisions.

Importance of the New Regulation

The new Regulation is an important step forward in Andorra’s efforts to enhance its international tax cooperation and provide greater certainty to taxpayers. The Regulation will help to ensure that disputes between taxpayers and the Andorran Tax Authorities are resolved in a fair and efficient manner.

The Regulation is also expected to be beneficial to Andorra’s economy by making it more attractive to foreign investors and businesses. By providing a clear and predictable framework for resolving tax disputes, the Regulation will help to reduce the risk of double taxation and create a more favorable environment for doing business in Andorra.

For further information, please consult the following resources:

El Govern aprova un nou Reglament de procediments d’arranjament per a la resolució de conflictes en l’àmbit de la doble imposició

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