Tunisia. Total MAP Caseload. Average time needed to close MAP cases (in months) n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a.

Transcription

1 Tunisia 5 4 Total MAP Caseload Cases started before 1 January 2017 Transfer pricing cases Other cases 2017 start inventory Cases started Cases closed 2017 end inventory Cases started as from 1 January start inventory Cases started Cases closed 2017 end inventory 0 Start inventory on Cases started Cases closed End inventory on Transfer pricing cases Other cases Cases started as from 1 January 2017 Cases started before 1 January 2017 Average time needed to close MAP cases (in months) Cases started before 1 January 2017 Transfer pricing cases Other cases Average time n.a. n.a. Cases started as from 1 January 2017 Transfer pricing cases Other cases Start to End Receipt to Start Start to Milestone 1 Milestone 1 to End n.a. n.a. n.a. n.a. n.a. n.a. n.a. n.a. Tunisia MAP Statistics Page 1/8

2 MAP Outcomes Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving that there is no no including to disagree any other outcome Total Transfer pricing cases (all) Cases started before 1 January Cases started as from 1 January Other cases (all) Cases started before 1 January Cases started as from 1 January All cases Tunisia MAP Statistics Page 2/8

3 Annex A MAP Statistics Reporting for the 2017 Reporting Period (1 January 2017 to 31 December 2017) for Pre-2017 Cases Tunisia Row 1 category of cases no. of pre-2017 cases in MAP inventory on 1 January 2017 denied MAP access objection is not justified withdrawn by taxpayer number of pre-2017 cases closed during the reporting period by outcome: unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving that there is no taxation not in no including to disagree any other outcome Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 10 Column 11 Column 12 Column 13 Column 14 Attribution/ Allocation n.a. Row 2 Others n.a. Row 3 Total n.a. 1) a MAP case was considered as such when a taxpayer submits a request to challenge the taxation paid in Tunisia or a contracting state and that Tunisia considers such taxation is not levied in with the entered into or when the competent authority of a contracting state contacts Tunisia for a case where taxation is not in. 2) Tunisia has followed the same definition of MAP cass as the one existing in the MAP statistics reporting framework 3) Tunisia has adopted the same categorisation of MAP cases, whereby attribution/allocation MAP cases are cases falling under article 7 of the OECD Model Tax Convention (Profit allocation to permanent establishments) or Article 9 (associated enterprises). 4) no pre-2017 cases were closed in ) the cases reported here are either being under analysis or dealt with by the administration in charge of the reimbursement, and at this stage no notification was sent to the taxpayer. no. of pre cases remaining in on MAP inventory on 31 December 2017 average time taken (in months) for closing pre cases during the reporting period Tunisia MAP Statistics Page 3/8

4 Table 1: Attribution / Allocation MAP Cases number of post-2016 cases closed during the reporting period by outcome: Treaty Partner 2016 cases in MAP inventory on 1 January cases started during the reporting period denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation eliminated / fully resolving partially double taxation / partially resolving taxation not in that there is no no including to disagree any other outcome 2016 cases remaining in MAP inventory on 31 December 2017 Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 10 Column 11 Column 12 Column 13 Column 14 Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Notes Tunisia MAP Statistics Page 4/8

5 denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving taxation not in that there is no taxation not in no including to disagree Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 10 Column 11 Column 12 Column 13 Column 14 Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Treaty Partner 2016 cases in MAP inventory on 1 January cases started during the reporting period Table 2: Other MAP Cases number of post-2016 cases closed during the reporting period by outcome any other outcome 2016 cases remaining in MAP inventory on 31 December 2017 Tunisia MAP Statistics Page 5/8

6 Table 1: Attribution / Allocation MAP Cases Row 2 Row 3 "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Column 5 Treaty Partners (de minimis rule applies) Treaty Partners (Others) Treaty Partner average time taken (in months) for post-2016 cases from: Total Average Time n.a. n.a. n.a. n.a. Tunisia MAP Statistics Page 6/8

7 Table 2: Other MAP Cases Row 2 Row 3 Treaty Partners (de minimis rule applies) Treaty Partners (Others) "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Column 5 Total Average Time n.a. n.a. n.a. n.a. Treaty Partner average time taken (in months) for post-2016 cases from: Tunisia MAP Statistics Page 7/8

8 "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Row 1 Total Average Time n.a. n.a. n.a. n.a. Table 3: All MAP Cases average time taken (in months) for post-2016 cases from: Tunisia MAP Statistics Page 8/8