Resolving Tax Treaty and Transfer Pricing Disputes through Mutual Agreement Procedure (MAP)

Master the MAP process to tackle tax treaty disputes, mitigate transfer pricing risks, and advocate for a stronger MAP Program.


Category

Legal Writing and Oral Advocacy

Credit Unit

2

DURATION

249:00

EXPIRATION DATE

11/20/2027 12:00:00 AM

OVERVIEW

When a tax assessment arises from an erroneous treaty interpretation or a transfer pricing adjustment increases a related party’s income, tax practitioners are not limited to domestic legal remedies such as requesting a ruling, filing an administrative protest, or seeking a tax court review.

The Mutual Agreement Procedure (MAP), a distinct administrative process separate from the Tax Code’s dispute resolution mechanisms, plays a crucial role in eliminating double taxation and mitigating transfer pricing risks.

This course is designed to deepen your understanding of the MAP process—especially if you work with multinational enterprises (MNEs) and international clients—and equip you with practical skills to initiate MAP requests in appropriate cases.

Additionally, this course supports tax practitioners in advocating for a well-structured and effective MAP Program in the country.

PLEASE TAKE TIME TO READ THIS:

This course was developed based on the UN and OECD Guidelines for MAP at a time when the BIR had not yet issued RR 10-2022. Since RR 10-2022 was introduced after the course was created, use this course as a foundational guide to understanding MAP, but always refer to the latest Revenue Regulations for current rules and procedures.

Course Status

AVAILABLE NOW

Course Price

₱886.00

when you avail the Full Compliance (36 Units) bundle

₱1,200.00

Regular price for 1 credit unit course

Lecturer

ATTY. CHARADINE S. BANDON

Founding Partner, Ortiz and Bandon Law Offices

Charadine is a founding partner of Ortiz and Bandon Law Offices, a boutique firm specializing in taxation law. She is also a Tax Professor at the University of the Philippines (UP) College of Law, an MCLE lecturer on International Tax at the UP Institute for the Administration of Justice, and a lecturer at the Asian Institute of Taxation. Charadine was a former tax treaty negotiator for the Philippines and was responsible for formulating the technical positions of the Philippines in treaty negotiations.