This information must be provided with respect to “reporting accounts”, which are, subject to certain exceptions, Nigerian accounts held by persons residing in a foreign country with which Nigeria has signed the corresponding information exchange agreement. The MAP is a dispute resolution mechanism (in legally enforceable tax contracts that can be implemented in Nigeria) whereby a Nigerian taxpayer can ask a competent authority (the minister of finance or his agent) in Nigeria to engage the competent authorities (CAs) of other countries with which Nigeria has tax agreements (contractants) in order to find a reciprocal solution to the tax issues concerning that taxpayer. The POP guidelines require the subject to provide the necessary assistance to Nigeria`s competent authority as part of the map process. The taxpayer should be informed by Nigeria`s competent authority if the two countries participating in the map procedure reach an agreement. The contract is concluded only with the written agreement of the subject. The Competent Authority (CA) appoints the minister responsible for the funding or its authorized representative. The Nigerian Board is expected to intervene with the CAs of the contracting parties to resolve disputes over the interpretation or application of the provisions of the tax contract. Notwithstanding the arbitration procedures provided for by the domestic law of the States Parties, the subject may bring an action before the aid agency of one of the two States parties. The Minister of Finance in Nigeria may assign an authorized representative of this task, i.e. a competent delegated authority.
The Mutual Agreement (MAP) procedure is a dispute resolution procedure in which the Nigerian competent authority and the competent foreign authority (CA) settle tax disputes involving a taxpayer. This may include double taxation of a taxpayer and the interpretation and application of a specific tax contract. The article on POPs in Nigeria`s tax treaties also acknowledges this reconciliation procedure. A MAP is often moved between two CAs. Nevertheless, the Nigerian CA can host a multilateral POP of three or more CAs. The strengths of the procedure or requirements for the initiation of POPs are listed below: The Federal Inland Revenue Service (FIRS) has published guidelines for the Mutual Agreement Procedure (MAP) for the resolution of disputes related to the income tax agreement. The POP Dispute Resolution Instrument allows tax authorities to resolve disputes over the implementation of the Income Tax Convention`s measures to combat double taxation. Nigeria signed the MLI and also presented its position on LMIs, which lists TDDs with 19 contracting parties for amendment. These include agreements that are already in place and are not yet in force (for example. B DTTs with Korea, Mauritius, United Arab Emirates). In addition, of the 19 agreements, 13 contracting parties (including Belgium, Canada, China, the Netherlands and the United Kingdom) have all listed their DTTs with Nigeria for an amendment under the MLI.
Nigeria and its contractual partners must then agree on parts of their proposals that do not coincide.