Mutual Agreement Procedure (MAP)
Any national, resident, or domestic corporation of the Republic of Korea, any nonresident or foreign corporation may apply for commencing the MAP to any of the following persons.
- 1.The Minister of Economy and Finance where it is necessary to consult with the other Contracting State on the application and interpretation of the tax treaty.
- 2.The Commissioner of the National Tax Service where any tax has been or is likely to be assessed by the tax authority of the other Contracting State, not in compliance with the provisions of the tax treaty.
- 3.The Commissioner of the National Tax Service where a tax adjustment is required under the tax treaty between the Republic of Korea and the other Contracting State.
Where the mutual agreement procedure has commenced, the period from the commencement date to the closing date of the mutual agreement procedure shall be excluded from the period for requesting administrative appeal or litigation. Furthermore, the head of the tax office having jurisdiction over the place for tax payment may defer either a notice of the amount of tax or the collection of tax only where the other Contracting State allows such deferment in the course of the MAP.
* For more information, please refer to “Guidance on Mutual Agreement Procedure for Taxpayers”
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